Tesoro Refining & Marketing Co. LLC v. City of Carson

Summary

The California Supreme Court held that the Government Claims Act occupies the entire field of presentation requirements for claims for money or damages against local public entities, including claims for local tax refunds, and therefore preempts the City of Carson's mandatory administrative refund procedures. Because a written request for a refund of the City's oil industry business license tax is a 'claim for money or damages' under the GCA, Municipal Code sections 63515 and 63523 — requiring a refund request to the finance director and an appeal to the city manager — impose additional presentation requirements beyond the GCA and are field-preempted; a taxpayer need not exhaust them before filing a GCA claim and suing for refund. The Court of Appeal's contrary judgment was reversed with directions to overrule the City's demurrer.