This case raises the question of whether revenue generated from contracts between counties and private businesses amounts to a tax on the people who use the services provided by the contractor.  CSAC’s amicus brief argues that there is significant legal and policy support for such contractual arrangements, and that the revenue generated therefrom is not a tax on the payor.  CSAC’s brief was drafted by Joshua Heinlein and Jeffrey Michalowski in the San Diego County Counsel’s Office.