Can Eminent Domain Cases Rely on Assessor Handbooks Regarding Valuation Questions?

Over my career, I’ve come across an eminent domain case or appraiser that cited to the State Board of Equalization Assessors’ Handbook as authority regarding a valuation proposition.  This seemed odd to me.  However, I recently learned the reason why.

In the case of Prudential Ins. Co. v. City and County of San Francisco (1987) 191 Cal.App.3d 1142, the court pointed out that these handbooks have been “relied upon by the courts in interpreting valuation questions posed by the state Constitution and statutes (citations) and have been accorded ‘great weight’ in this regard.”  More recently, the court in the eminent domain case of San Diego Gas Electric Company v. Schmidt (2014) 228 Cal.App.4th 1280 confirmed that “[c]ourts may rely upon assessor handbooks in the interpretation of valuation questions.” 

Query if this can be expanded to mean that assessor cases themselves may be relied upon as authority in an eminent domain case?  Let me know what you think.

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