The city of Los Angeles, under the authority of the "Public Works and Utility Act" of California, passed two ordinances levying special assessments for street lighting purposes upon abutting property specially benefited according to the front foot rule. The validity of the ordinance ordering the necessary lighting posts and appliances, which were installed before the present proceeding was brought, was conceded. The other ordinance provided for the furnishing of electric current to light the public streets for a period of fourteen months. This was contested by the plaintiff, who owned three lots subject to the assessment, on the ground that electric current, being evanescent and impermanent, was not the kind of public improvement for which special assessments may be levied. The court held that the cost of furnishing electric current could be assessed against the benefited property. Roberts v. City of Los Angeles, (Cal. 1936) 61 P. (2d) 323.
Herbert J. Bloom,
TAXATION - SPECIAL ASSESSMENTS FOR STREET LIGHTING,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol35/iss5/21