In Amador Valley Joint Union High Sch. Dist. v. State Bd. of Equalization (1978) 22 Cal.3d 208, the California Supreme Court upheld the constitutionality of article XIII A and rejected various challenges to the validity of the initiative measure. But the Amador court was careful to point out that it was not deciding the potential impact of every provision of article XIII A. Thus, the merits of the dispute over the application of article XIII A to the unsecured tax rolls can be determined appropriately in actions for tax refunds filed by individual taxpayers pursuant to the provisions of Revenue and Taxation Code section 5140.