The California Court of Appeal held that taxpayers who sought judicial relief after the denial of their individually filed tax refund requests could proceed on a classwide basis without first filing a class claim for a refund because they strictly complied with administrative procedures as required by Cal. Const., art. XIII, § 32, and sufficiently exhausted administrative remedies under Rev. & Tax. Code, § 19322, by individually filing their refund claims. The Court of Appeal also specifically ordered certification of the class, which was the first time a class had been certified in an action against the Franchise Tax Board in 30 years.