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Thursday, September 3, 2026Bay Area Market: Coverage updated daily

California Supreme Court says cities can’t add extra hurdles to tax refunds

The California Supreme Court ruled that cities can’t make taxpayers complete extra procedures, handing Marathon Petroleum a win in its tax battle with Carson.

San Francisco Bay Area homes and neighborhoods
Curated News BriefBased on original reporting by CalMatters Housing (August 11, 2026). The summary below is the Journal’s; the local analysis is original commentary by Omar Murillo.

According to CalMatters Housing, California's Supreme Court just handed down a significant decision about how cities can handle tax disputes with large corporations. The case involved Marathon Petroleum, which operates a major refinery in Carson, and the question at the heart of it was pretty straightforward: does a company have to jump through a city's local hoops before it can file for a tax refund in court, or can it go straight to state law? The court sided with Marathon, ruling that cities can't force taxpayers to complete their own internal procedures first.

The actual dispute between Marathon and Carson goes back to a business tax on oil refineries that Carson voters approved years ago. The city later audited Marathon's payments and claimed the company owed significantly more in taxes, arguing that Marathon had underestimated how much of its business activity actually occurred within Carson's borders rather than in nearby Wilmington or elsewhere. Marathon disagreed, paid what the city demanded, but then filed for a refund under state law instead of going through Carson's local appeals process.

Lower courts in California had backed Carson's position that Marathon should have used the city's own process first. But the state supreme court overturned those decisions, deciding that the state's Government Claims Act was designed to let companies pursue refunds through the court system without being forced into lengthy local procedures. Business groups supporting Marathon had argued that local processes could become overly complicated, forcing companies to navigate what they called a complicated maze of different rules and requirements.

While this court decision is technically a procedural victory for Marathon, it doesn't actually settle the main argument about whether Carson properly calculated the taxes in the first place. However, the timing and the ruling seem to have moved things along. Right after the court decision came down, Carson's city council took action to withdraw a separate ballot measure that would have allowed the city to charge refineries based on how much oil they process, a move that Marathon's spokesperson had warned would have serious consequences for the company's California operations. That withdrawal appears to be connected to movement toward a settlement between the city and Marathon that's reportedly valued at substantial dollars.

What I'm seeing locally is that this decision signals how important it is for businesses to understand their rights when dealing with local tax disputes. For Bay Area property owners and investors, this ruling reminds us that state law sometimes trumps local procedures when it comes to pursuing refunds, which could matter if you ever find yourself in a tax disagreement with your city. It's a good reminder that knowing your options and understanding which rules apply can make a real difference in resolving these matters efficiently.