Morgan

Opinion of the Court by Kruger, J.

Under California law, a person who wants to challenge a tax ordinarily must first pay the tax and then seek available relief from tax authorities; if that effort is unsuccessful, the person may then file a tax refund action in court. (E.g., Rev. & Tax. Code, §§ 5097, 5140; see generally Steinhart v. County of Los Angeles (2010) 47 Cal.4th 1298, 1307–1308.) Here we consider how these tax-challenge procedures apply in a dispute concerning a unique financing arrangement in which individuals repay funds in the form of taxes. The arrangements at issue owe their existence to California’s Property Assessed Clean Energy (PACE) program (Stats. 2008, ch. 159, §§ 1–2, p. 523 (Assem. Bill No. 811)), a program that allows local governments to provide homeowners with financing for energy efficiency home improvements in exchange for a voluntary special assessment added to their property taxes and secured by a lien on their real property. Although many local governments have adopted the PACE program, few run the program themselves; most have contracted with private companies. Plaintiffs are homeowners who have entered into PACE contracts administered by private…