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Plaintiffs challenge the validity of Measure A on the November 2025 ballot.
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LAW OFFICES OF JASON A. BEZIS California State Bar No. 225641 3661-B Mosswood Drive Lafayette, CA 94549-3509 (925) 708-7073 Jason@BezisLaw.com Attorneys for Plaintiffs SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SANTA CLARA SILICON VALLEY TAXPAYERS | Case No. 26CV483689 ASSOCIATION, INC., a California mutual | benefit corporation; LIBERTARIAN | PARTY OF SANTA CLARA COUNTY; | RHONDA RICHARDS; CHRISTOPHER | SUMMONS ROBELL;KENNITA WATSON; and DAVID | CITATION JUDICIAL H. WOLEN | (Code of Civil Procedure Plaintiffs | � 860 et seq.) v. | | COUNTY OF SANTA CLARA; ALL | PERSONS INTERESTED IN THE MATTER | (Calendar Preference per OF MEASURE A, a transactions and use | Code Civ. Proc., � 867) tax increase on the November 4, 2025 | Santa Clara County ballot; and DOES | 1 THROUGH 100, inclusive | | Action Filed: January 2, 2026 Defendants | _______________________________ | NOTICE! YOU HAVE BEEN SUED. THE COURT MAY DECIDE AGAINST YOU WITHOUT YOUR BEING HEARD UNLESS YOU RESPOND NOT LATER THAN MARCH 19, 2026. READ THE INFORMATION BELOW. AVISO! USTED HA SIDO DEMANDADO. EL TRIBUNAL PUEDE DECIDIR CONTRA USTED SIN AUDIENCIA A MENOS QUE USTED RESPONDA NO MÁS TARDE QUE EL DÍA 19 DE MARZO, 2026. LEA LA INFORMACIÓN QUE SIGUE. TO ALL PERSONS INTERESTED IN THE MATTER OF THE VALIDITY OF MEASURE A ON THE NOVEMBER 4, 2025 SANTA CLARA COUNTY BALLOT: A civil complaint has been filed in the California Superior Court for the County of Santa Clara by plaintiffs Silicon Valley Taxpayers Association, Inc., Libertarian Party Of Santa Clara County, Rhonda Richards, Christopher Robell, Kennita Watson, and David H. Wolen against defendant County of Santa Clara and all interested persons in the matter for the purpose of determining the validity of Measure A, a transactions and use tax increase on the November 4, 2025 Santa Clara County ballot, and other matters related thereto. THE FOLLOWING IS A DETAILED SUMMARY OF THE MATTER SOUGHT TO BE INVALIDATED: Measure A on the November 4, 2025 ballot in Santa Clara County, the so-called "2026 County of Santa Clara Retail Transactions and Use Tax Ordinance," would authorize a new 0.625 percent (5/8 percent) general transactions and use (sales) tax providing approximately $330 million annually for five years, effective on April 1, 2026. Defendant COUNTY OF SANTA CLARA, acting by and through its Board of Supervisors at its December 9, 2025 meeting, declared that Measure A was passed. If Measure A were to take effect, the total sales tax rate would be 10.0 percent or higher in much of Santa Clara County, the highest sales tax rate ever in Santa Clara County history. Plaintiffs allege that Measure A must be invalidated and not implemented because California Revenue and Taxation Code section 7292.4, enacted via Senate Bill 335 (SB 335) in 2023, is an unconstitutional "local" or "special" statute, in violation of article IV, section 16 of the California Constitution. Measure A is an invalid tax because the total "sales tax" rate in Santa Clara County otherwise would exceed the limits on local transactions and use taxes set by Revenue and Taxation Code sections 7251.1, 7285.3, and 7285.92. Plaintiffs also allege that Measure A must be invalidated and not implemented because the Santa Clara County Board of Supervisors did not consolidate the Measure A general tax election with a regularly scheduled general election for members of the County Board of Supervisors, in violation of article XIII C, section 2, subdivision (b), of the California Constitution. November 4, 2025 was not a regularly scheduled general election date for members of the Santa Clara County Board of Supervisors. Plaintiffs also allege that Measure A is invalid because the County Board of Supervisors' declaration of "emergency" by resolution at the August 7, 2025 Board special meeting was not a legally sufficient "case of emergency" under the California Constitution, article XIII C, section 2, subdivision (b), and therefore the County Board of Supervisors could not place the Measure A general tax on the November 4, 2025 special election ballot. Plaintiffs also seek declaratory and injunctive relief based upon the aforementioned grounds. To be heard regarding this matter, you must file in this court a written response to the complaint by MARCH 19, 2026. Otherwise, plaintiffs may apply for entry of default and the relief sought by their complaint. You may obtain a copy of the complaint by contacting plaintiffs' counsel using the address or telephone number shown below. If you respond to contest or defend the validity of this matter, you will not be subject to punitive action such as wage garnishment or seizure of real or personal property. YOU MAY SEEK THE ADVICE OF AN ATTORNEY IN ANY MATTER CONNECTED WITH THE COMPLAINT OR THIS SUMMONS. SUCH ATTORNEY SHOULD BE CONSULTED PROMPTLY SO THAT YOUR PLEADING MAY BE FILED OR ENTERED WITHIN THE TIME REQUIRED BY THIS SUMMONS. SI USTED DESEA SOLICITAR EL CONSEJO DE UN ABOGADO EN ESTE ASUNTO, DEBERÁ HACERLO IMMEDIATAMENTE. TAL ABOGADO DEBERÁ SER CONSULTADO PRONTO PARA QUE SU REPUESTA ESCRITA PUEDA SER REGISTRADA DENTRO DEL TIEMPO REQUIERIDO POR ESTA CITACIÓN JUDICIAL. The name and address of the Court is (el nombre y direcci¢n del Tribunal es): Superior Court, County of Santa Clara 191 North First Street San Jos, CA 95113 CASE NUMBER (N£mero del Caso): 26CV483689 The name, address, and telephone number of Plaintiffs' attorney is (el nombre, la direcci¢n y el n£mero de telfono del abogado de los demandantes es): Law Offices of Jason A. Bezis 3661-B Mosswood Drive Lafayette, CA 94549-3509 Tel: (925) 708-7073 DATED: 1/29/2026 By: S. Rodriguez [SEAL] Superior Court Clerk SJMN 6947888 February 12, 19, 26, 2026
