The issue in this case is whether the district court erred in granting a preliminary injunction preventing the California State Board of Equalization (Board) from collecting an amended property-tax bill levied on appellees' railroad cars. The district court found that the imposition of the additional tax impermissibly conflicted with Sec. 306 of the Railroad Revitalization and Regulatory Reform Act of 1976 (the 4-R Act), current version at 49 U.S.C. Sec. 115031, which prohibits the taxation of rail-transportation property at a rate higher than the rate generally applicable to commercial and industrial property in the same assessment jurisdiction. We concur in the district court's underlying conclusions that Sec. 11503 applies to the Board's attempt to collect the additional tax, that Sec. 11503 authorizes a district court to enjoin tax-rate discrimination, and that, under the circumstances of this case, the traditional prerequisites for preliminary injunction need not be satisfied. We find, however, that the district court's method of selecting the tax rate generally applicable to commercial and industrial property, which is the necessary first step in determining the existence of tax-rate discrimination, was defective. We therefore affirm in part, and vacate and remand in part.

California classifies and taxes the bulk of its property as "secured" or "unsecured."3 The secured and unsecured tax rolls each contain both real and personal property. The secured tax rate is calculated anew each fiscal year, while the unsecured tax rate is equal to the tax rate applied to secured property in the preceding fiscal year. Cal. Const. art. XIII, Sec. 12; Cal.Rev. & Tax Code Sec. 2905 (West 1970 & Supp.1982).

Private railroad cars are considered personal property and are subject to a separate tax under California's Private Railroad Car Tax Law, Cal.Rev. & Tax Code Sec. 11401 (West 1970 & Supp.1982). The tax rate for private railroad cars is the average rate of general property taxation for the preceding year, id., which is basically the weighted average of the prior year's secured and unsecured tax rates.

In June 1978, California voters approved Proposition 13, Cal. Const. art. XIIIA, which limits the tax rate applicable to real property. Relying on Article XIII, section 2, of the California Constitution, which requires that personal property not be taxed at a rate higher than that applied to real property in the same jurisdiction, the Board at that time determined that the Proposition 13 tax-rate limitation must also be applied to limit the tax on private railroad cars. Accordingly, it levied a tax on railroad cars owned by the Trailer Train Company and the Railbox Company (the Companies) for fiscal year 1978-79 at the lower Proposition 13 rate, estimated at $4.85 per hundred dollars of assessed value, instead of the usual rate prescribed by the Private Railroad Car Tax Law. This latter tax rate, calculated by taking the weighted average of the secured and unsecured rates for fiscal year 1977-78, would have amounted to $10.68 per hundred dollars of assessed value.

The situation remained unchanged until August 1980, when the California Supreme Court ruled that the Proposition 13 tax-rate limitation did not apply to real or personal property on the 1978-79 unsecured roll. Board of Supervisors v. Lonergan, 27 Cal. 3d 855, 616 P.2d 802, 167 Cal. Rptr. 820 (1980), cert. denied, 450 U.S. 918, 101 S. Ct. 1362, 67 L. Ed. 2d 344 (1981). The Board interpreted Lonergan as rendering improper its application of the Proposition 13 tax-rate limitation to private railroad cars for fiscal year 1978-79.4 Therefore, in October 1980, the Board recalculated the tax on private railroad cars for 1978-79, this time using the rate of $10.68 per hundred dollars of assessed value--the rate the Board would have initially applied had it not believed Proposition 13 to be controlling. The Board levied and attempted to collect from the Companies an additional tax equal to the difference between the tax computed at the $10.68 rate and the tax previously paid at the $4.85 rate.

The Companies sued to enjoin the Board from collecting this additional tax on the ground that the additional tax discriminated against owners of rail-transportation property in violation of 49 U.S.C. Sec. 11503. The district court granted the Companies' motion for preliminary injunction, and the Board filed this appeal.

On appeal, the Board argues that the district court erred in granting the preliminary injunction because (1) the alleged discriminatory tax was imposed before the effective date of Sec. 11503; (2) Sec. 11503 does not authorize a district court to enjoin tax-rate discrimination; (3) there was no tax-rate discrimination; and (4) the necessary preconditions for the grant of a preliminary injunction have not been met.

The 4-R Act was passed in 1976, but the effective date of Sec. 11503 was postponed for three years to February 1979. Pub.L. No. 94-210, Sec. 306, 90 Stat. 31, 54 (1976). The assessment of the Companies' property on which the additional tax is based was made in 1978, several months before the effective date of Sec. 11503. The Board, however, tried to collect this additional tax in 1980, after the effective date of Sec. 11503. Since Sec. 11503(b) prohibits not only assessments which discriminate against rail-transportation property, but also the collection of taxes based on discriminatory tax rates, Sec. 11503 appears clearly to apply to the Board's collection of the additional tax.

The Board puts forth a creative argument in an attempt to avoid the application of Sec. 11503. It argues that since the additional tax is based on assessments made in 1978 and is intended merely to correct its mistaken calculation of taxes owed for that year, the additional tax should relate back to 1978 and thus be deemed to have been imposed before the effective date of Sec. 11503.

The Board's relation-back argument is not persuasive. Congress' purpose in postponing the effective date of Sec. 11503 was to afford the states sufficient time to comply with the statute's prohibition against discriminatory tax treatment of railroad property. H.R.Rep. No. 725, 94th Cong., 1st Sess. 76 (1975). It was not to provide states with an additional opportunity to impose and collect discriminatory taxes. Allowing the additional tax to relate back to 1978 and thus escape the application of Sec. 11503 not only would subvert Congress' purpose in postponing the statute's effective date, but also would run counter to the basic policy of Sec. 11503 to prohibit discriminatory taxation of railroad property.5

Whether a district court has jurisdiction under Sec. 11503 to enjoin the use of a discriminatory tax-rate presents a sticky exercise in statutory interpretation. Subsection (b) of Sec. 11503 prohibits, among other things, the discriminatory assessment of rail-transportation property and the levy or collection of a tax based on discriminatory tax rates. The first sentence of subsection (c) then grants the district court jurisdiction to prevent a violation of subsection (b). But the second sentence of subsection (c) provides that "[r]elief may be granted under this subsection only if the ratio of assessed value to true market value of rail transportation property exceeds by at least 5 percent, the ratio of assessed value to true market value of other commercial and industrial property in the same assessment jurisdiction." (Emphasis added.) Under a narrow, literal reading of Sec. 11503, it would appear that, while tax-rate discrimination constitutes a violation of the statute, injunctive relief can only be granted if the tax-rate discrimination is accompanied by an assessment-ratio discrimination of at least 5 percent.

A statute, however, should not be interpreted so narrowly as to defeat its obvious intent. In interpreting a statute, the court's objective should be to ascertain congressional intent and give effect to legislative will. Philbrook v. Glodgett, 421 U.S. 707, 713-14, 95 S. Ct. 1893, 1898, 44 L. Ed. 2d 525 (1974); United States v. American Trucking Associations, Inc., 310 U.S. 534, 542, 60 S. Ct. 1059, 1063, 84 L. Ed. 1345 (1940).

The purpose of Sec. 11503 is "to eliminate the long-standing burden on interstate commerce resulting from discriminatory State and local taxation of common and contract carrier transportation property."6 Congress recognized that discrimination against rail-transportation property can result from either assessment variation or tax-rate variation. S.Rep. No. 1085, 92d Cong., 2d Sess. 5 (1972); S.Rep. No. 630, 91st Cong., 1st Sess. 3 (1969). It thus drafted Sec. 11503 to prohibit the discriminatory use of either of these methods. Congress also believed that a federal court remedy for carriers subject to discriminatory taxation was necessary because state courts were not providing them with a plain, speedy, and efficient remedy. S.Rep. No. 1085, 92d Cong., 2d Sess. 4-5 (1972); S.Rep. No. 630, 91st Cong., 1st Sess. 6-7 (1969). It thus included in Sec. 11503 a procedural component which authorizes victims of discrimination to seek injunctive relief in federal court.

Given the basic concerns motivating Congress' enactment of Sec. 11503, Congress could not have intended that the statute be construed as authorizing the district court to enjoin a tax-rate discrimination only when it is accompanied by an assessment-ratio discrimination. Such a literal reading of Sec. 11503 ignores Congress' recognition that discriminatory taxation of carriers can result from either assessment-ratio or tax-rate discrimination. It also undermines Congress' intent to provide discrimination victims with an injunctive federal-court remedy by placing arbitrary limits on those who could apply for such relief.

The literal reading of Sec. 11503 leads to the absurd result that a district court could enjoin the use of an assessment-ratio excessive by 6 percent, but would be powerless to enjoin the use of a tax-rate excessive by 80 percent unless it were also accompanied by the use of an excessive assessment ratio. A court may look beyond the express language of a statute where a literal interpretation thwarts the purpose of the overall statutory scheme or leads to an absurd result. Cantwell v. County of San Mateo, 631 F.2d 631, 634 (9th Cir.1980), cert. denied, 450 U.S. 998, 101 S. Ct. 1703, 68 L. Ed. 2d 199 (1981); International Telephone and Telegraph Corp. v. General Telephone and Electronics Corp., 518 F.2d 913, 917-18 (9th Cir.1975); see United States v. American Trucking Associations, Inc., 310 U.S. at 543-44, 60 S.Ct. at 1064. In view of Congress' clear purpose in enacting Sec. 11503, we hold that the statute is properly construed as granting the district court jurisdiction to enjoin a tax-rate discrimination independent of any assessment-ratio discrimination.7

Section 11503(b)(3) prohibits the taxation of rail-transportation property at a tax rate higher than the tax rate generally applicable to commercial and industrial property in the same assessment jurisdiction.8 To discern whether California has imposed a discriminatory tax rate in violation of Sec. 11503(b)(3), it is necessary to compare the tax rate applied to the Companies' railroad cars with that generally applicable to commercial and industrial property. Our task is complicated by the fact that, while the rate applied to the Companies' railroad cars is readily available ($10.68 per $100.00 of assessed value), California has no specific tax rate for commercial and industrial property. Instead, California classifies and taxes its property as "secured" or "unsecured," with commercial and industrial property appearing on both the secured and unsecured rolls.9 The secured rate for the year in issue, the 1978-79 fiscal year, was $4.70 per hundred dollars of assessed value. The unsecured rate for that year, under the Lonergan decision, should have been set at $10.63 per hundred dollars of assessed value.10

Neither Sec. 11503 nor its legislative history provides much guidance as to what should be done when a specific rate generally applicable to commercial and industrial property is not readily apparent. We find, however, that for this case the following approach best conforms to the statute's language and fulfills its intent: The 1978-79 secured and unsecured rolls must be examined to determine which roll contained the majority of California's commercial and industrial property. The tax rate applicable to the roll that contained the majority of the commercial and industrial property shall be deemed the rate generally applicable to commercial and industrial property and shall serve as the base rate for comparison against the Companies' $10.68 rate.11 If the determination of which roll contained the majority of the state's commercial and industrial property in the 1978-79 fiscal year is not possible, the average tax rate for all property shall be used as the basis for comparison.

In selecting the base rate for comparison against the Companies' rate, the district court failed to focus on the crucial issue of which tax roll contained the majority of the state's commercial and industrial property. Instead, the court apparently assumed that since California has no specific rate for commercial and industrial property, the rate generally applicable to commercial and industrial property could not be determined.12 2] It then interpreted the latter portion of Sec. 11503(c) as requiring the use of the average tax rate for all property as the basis for comparison in this assumed situation.13

Under our reading of Sec. 11503, the fact that California has no specific rate for commercial and industrial property does not mean that a rate generally applicable to such property cannot be determined. The absence of a specific rate merely requires that the inquiry be shifted to which roll, the secured or unsecured, contained the majority of the state's commercial and industrial property in the 1978-79 fiscal year.

Because the district court misinterpreted Sec. 11503, it failed to make this crucial inquiry. Its method of selecting the base rate for comparison against the Companies' rate was thus materially flawed and its consequent finding of discrimination cannot be accepted. Unfortunately, the record does not contain sufficient evidence for us independently to determine which roll contained the majority of the state's commercial and industrial property. The case must therefore be remanded for that determination. On remand, we instruct the district court to adopt the approach we have set forth in this opinion in selecting the proper base rate for comparison.14 Such a selection is, of course, a necessary step in determining whether California has imposed a discriminatory tax rate on the Companies' railroad cars.

Finally, the Board argues that the district court erred in granting the preliminary injunction without first requiring the establishment of the standard equitable prerequisites for such relief.15 We disagree.

The standard requirements for equitable relief need not be satisfied when an injunction is sought to prevent the violation of a federal statute which specifically provides for injunctive relief. Atchison, Topeka and Santa Fe Railway v. Lennen, 640 F.2d 255, 259-61 (10th Cir.1981); see United States v. City and County of San Francisco, 310 U.S. 16, 30-31, 60 S. Ct. 749, 756-57, 84 L. Ed. 1050 (1940). Section 11503 clearly falls within this exception because its subsection (c) specifically authorizes a district court to grant injunctive relief to prevent a violation of the statute.16 See Atchison, Topeka and Santa Fe Railway v. Lennen, 640 F.2d 255 (expressly applying exception to Sec. 11503). The Board provides no convincing reason why this exception should not apply in the present case.

We are in basic agreement with the district court with respect to the following findings: (1) Section 11503 is fully applicable to the Board's attempt to collect the additional tax levied against the Companies' railroad cars; (2) the statute authorizes the district court to enjoin a tax-rate discrimination independent of any assessment-ratio discrimination; and (3) traditional prerequisites for equitable relief need not be satisfied before a preliminary injunction may be issued under Sec. 11503.

However, because we also find that the district court erred in selecting the tax rate generally applicable to commercial and industrial property, we cannot affirm its determination that the Board imposed a discriminatory tax rate on the Companies' railroad cars. Section 11503 requires that the rate generally applicable to commercial and industrial property be used as the base tax rate for comparison against the Companies' rate for purposes of determining discrimination. On remand we instruct the district court to ascertain which tax roll, the secured or unsecured, contained the majority of California's commercial and industrial property in fiscal year 1978-79. The tax rate applicable to the selected roll shall be the rate generally applicable to commercial and industrial property and shall be used as the base rate for comparison against the Companies' rate. If it is impossible to determine which roll contained the majority of the state's commercial and industrial property, the average tax rate for all property shall be used as the basis for comparison.

AFFIRMED in part; VACATED and REMANDED in part.