The First Appellate District granted in part a petition for writ of mandate and remanded. The court held that qualifying cities entitled to tax equity allocation are not afforded the same treatment, for purposes of apportioning the burden of property tax shifts, under the 1992, 1993 and 2004 Education Revenue Augmentation Fund tax revenue shifts.

At the end of 1995, the Santa Cruz County Auditor-Controller notified the City of Scotts Valley that the city would receive property tax revenues under the Tax Equity Allocation (TEA) statute.