District

This case involves interpretation of the Citrus Pest District Control Law (Pest Control Law), codified at Food and Agricultural Code section 8401 et seq. We recently addressed the Pest Control Law at length in People ex rel. Lockyer v. Sun Pacific Farming Co. (2000) 77 Cal.App.4th 619 [ 92 Cal.Rptr.2d 115 ]. In that case we held, in part, that the appropriate procedure for challenging the effectiveness of the Central California Tristeza Eradication Agency’s plan for control and eradication of the citrus tristeza virus (CTV) is to first exhaust one’s remedies by challenging the budget before the relevant pest control district. We now determine whether this exhaustion requirement also applies to challenges to assessments imposed under the Pest Control Law. We find that it does.

Procedural and Factual Histories

Wallich’s Ranch Co. (Wallich’s Ranch) brought an action against the Kern County Citrus Pest Control District (the District), the Central California Tristeza Eradication Agency (the Agency), and the County of Kern (the County) (collectively defendants) for declaratory and injunctive relief and a refund of the assessments/taxes imposed upon it from 1995 through 1998.…