Ardon

In this case, we must decide whether Government Code section 910 (section 910) allows taxpayers to file a class action claim against a municipal governmental entity for the refund of local taxes. In City of San Jose v. Superior Court (1974) 12 Cal.3d 447, 455 [ 115 Cal.Rptr. 797 , 525 P.2d 701 ] (City of San Jose), we held that section 910 permits a litigant to bring a class claim against a local government. We later held in Woosley v. State of California (1992) 3 Cal.4th 758, 792 [ 13 Cal.Rptr.2d 30 , 838 P.2d 758 ] (Woosley), however, that class claims to recover tax refunds are not permitted in certain situations because article XIII, section 32 of the California Constitution prevents the judiciary “from expanding the methods for seeking tax refunds expressly provided by the Legislature.” As we explain, neither Woosley , which concerned the interpretation of statutes other than section 910, nor article XIII, section 32 of the California Constitution, applies to our determination of whether section 910 permits class claims that seek the refund of local taxes. We therefore conclude that the reasoning of City of San Jose , which permitted a class claim against a municipal…