A California Court of Appeal held that a telephone company suing for a refund of centrally assessed property taxes was not statutorily required to name as a defendant every county in which it owned property and that the absent counties were not indispensable parties required to be joined in the suit. The California Constitution requires the State Board of Equalization (BOE) to assess certain property at the state level, including property owned or used by telephone companies. A taxpayer challenging such an assessment must first exhaust its administrative remedies with the BOE. If the taxpayer files a refund suit, it must file a single complaint “with all parties joined therein” and “name the [BOE] and the county or counties” under California Revenue and Taxation Code Section 5148. The taxpayer owned property in 38 California counties, but filed its complaint against only the BOE and the nine counties from which it sought a refund. The BOE demurred on the grounds that Section 5148 required the taxpayer to name the other 29 counties and that the absent counties were indispensable parties required to be joined under California Code of Civil Procedure Section 389. In reversing the trial court’s decision, the California Court of Appeal first applied the plain meaning rule to Section 5148 and clarified that, under the statute, the relevant composition of the “parties” stemmed from the action brought by the taxpayer, not the underlying administrative assessment dispute from which the action arose. Furthermore, the statute’s reference to “county or counties” illustrated that the Legislature contemplated a scenario in which a taxpayer might seek recovery of taxes from only a single county despite the fact that centrally assessed property typically lies in multiple counties. Looking at the legislative history of Section 5148, the court found that the purpose of the statute was not to impose a rule that a taxpayer must file suit against all counties in which it owned property, but rather to streamline the appeals process by allowing taxpayers to name multiple counties in one complaint rather than sue each county individually. Accordingly, the court held that Section 5148 did not require the taxpayer to name in its complaint all counties in which it owned property and that substantial evidence did not exist to support the trial court’s finding that the 29 unnamed counties were indispensable parties required to be joined in the suit. In particular, the court found insufficient evidence that the absent counties would be affected by a change in the challenged assessment and that the absent parties’ interests would not be adequately protected by the nine named counties. Verizon California, Inc. v. Bd. of Equalization et al., No. C074179 (Cal. Ct. App. Oct. 15, 2014).