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Keywords

plaintiffdefendantappealtrialpleaclass actionjudicial review

plaintiffdefendantdamagesinjunctionappealtrialpleaclass actionjudicial review

Related Cases

Schoderbek v. Carlson, 113 Cal.App.3d 1029, 170 Cal.Rptr. 400

Facts

Fifteen named plaintiffs, representing approximately 138,000 homeowners, filed a class action against various Santa Clara County tax authorities challenging property tax assessment practices that began after Proposition 13 was enacted in 1978. The plaintiffs argued that the assessments were improper and sought a refund of local ad valorem property taxes. However, they did not allege that they had pursued their administrative remedies, which is a prerequisite for judicial review of property tax assessments.

Fifteen named plaintiffs in their own behalf and on behalf of persons similarly situated brought a class action for declaratory relief, writ of mandate, preliminary and permanent injunction and damages, naming the Assessor of Santa Clara County, Alfred Carlson, the former Assessor of Santa Clara County, the Director of Finance of Santa Clara County, the Tax Collector of Santa Clara County, the Board of Supervisors of Santa Clara County, the State of California and the State Board of Equalization as defendants.

Issue

Whether the plaintiffs could maintain a class action for a refund of property taxes without exhausting their administrative remedies.

Whether the plaintiffs may bring the instant action since they did not allege that they pursued their administrative remedies.

Rule

A general prerequisite to judicial review of a property tax assessment is the application for and denial of relief by the county board of equalization or assessment appeals board. A claim for refund must be filed before a suit for refund can be brought.

A general prerequisite to judicial review of a property tax assessment is application for and denial of relief by the county board of equalization or assessment appeals board.

Analysis

The court determined that the plaintiffs could not maintain their class action because they had not exhausted their administrative remedies. The plaintiffs argued that they should be excused from this requirement due to the large number of homeowners they represented, but the court found that they could have filed a claim for refund on behalf of themselves and the class members. The court emphasized that the administrative process must be followed before seeking judicial intervention.

We therefore conclude that plaintiffs may not bring the instant action because they have not exhausted their administrative remedies.

Conclusion

The court vacated the trial court's judgment and remanded the case with directions to dismiss the action if the plaintiffs could not plead that they had exhausted their administrative remedies.

The judgment of the trial court is vacated. The action is remanded to the superior court with directions to dismiss the action if plaintiffs cannot plead that they have exhausted their administrative remedies or a proper excuse therefor.

Who won?

Defendants prevailed in the case because the court found that the plaintiffs failed to exhaust their administrative remedies, which is a necessary step before seeking judicial relief.

Defendants allege that class claims for refund may not be filed to test the validity of local ad valorem property taxes.

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