Do Proposition 218 challenges to new taxes and fees require exhaustion of administrative remedies?  In this amicus brief, CSAC argues that the answer to that question is yes, and that the exhaustion requirement is needed to ensure that agencies can know challenges to their actions will be limited to those they have had opportunity to address.  The brief was drafted by Dan Hentschke in the Santa Barbara City Attorney’s Office, Lufti Kharuf at Best Best & Krieger in San Diego, and Michael Colantuono at Colantuono, Highsmith & Whatley in Grass Valley.