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Click here for the full text of this decision FACTS:The Cameron Appraisal District assessed ad valorem taxes against the owners of 34 travel trailers for the tax years 2000 and 2001. After some but not all filed unsuccessful administrative protests and then timely appeals in the district court, the latter 1. dismissed for lack of jurisdiction the claims by those who had not exhausted administrative remedies, 2. granted summary judgment against the remainder because their trailers were taxable as a matter of law, and 3. refused to certify a class action. The court of appeals reversed. HOLDING:Reversed and remanded. The Texas Tax Code provides detailed administrative procedures for those who would contest their property taxes. By mandating class certification of all claims, the court of appeals allowed taxpayers to bypass the statutorily required administrative remedies. A class action cannot be used to alter these statutory prerequisites to taxpayer recovery. The court disagrees with the court of appeals’ conclusion that the exhaustion requirements were inapplicable because purely legal and constitutional questions were involved here. In addition to claiming that taxing their trailers was unconstitutional, the taxpayers claim that their trailers were nontaxable “recreational vehicles” rather than taxable “manufactured homes” due to their size, shape and intended use. The taxpayers here are seeking more than a declaration that taxing trailers is unconstitutional – they are seeking to have their individual assessments set aside. That latter claim must be brought administratively. “By finding ‘no sound reason’ to require exhaustion . . . the court of appeals simply substituted its own judgment for that of the Legislature. Accordingly, the court of appeals erred in reversing the trial court’s partial dismissal and requiring certification of a class of taxpayers who had failed to pursue administrative remedies.” The court agrees, however, with the court of appeals that fact issues preclude finding the remaining taxpayers’ trailers taxable as a matter of law as “manufactured homes” rather than “recreational vehicles.” Whether a class can be certified as to those claims is a matter that must be decided by the trial court in the first instance. OPINION:Per curiam.

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