California, United States of America
The following excerpt is from Weatherford v. City of San Rafael, 2 Cal.5th 1241, 218 Cal.Rptr.3d 394, 395 P.3d 274 (Cal. 2017):
sue in this kind of case, for it clearly altered the common law, which required only that the plaintiff be a taxpayer supporting the governmental entity whose act is sought to be challenged" and did not impose a residency requirement. (Id . at p. 19, 51 Cal.Rptr. 881, 415 P.2d 769, citing Thomas v. Joplin (1910) 14 Cal.App. 662, 664-665, 112 P. 729.) Section 526a's requirement that an individual plaintiff be a "citizen resident therein," thus narrowed the scope of taxpayer standing relative to the common law.
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