In Pacific Gas & Electric Co. v. State Bd. of Equalization (1980) 27 Cal.3d 277, the plaintiffs filed an action for mandamus and declaratory relief to compel the Board to adjust the assessment of their property taxes. The court, however, held that article XIII, section 32 barred the action. In reaching its decision, the court rejected the plaintiffs' attempt to "circumvent" article XIII, section 32's "restraints on prepayment tax litigation by seeking only declaratory relief." (Pacific Gas & Electric, supra, 27 Cal.3d at p. 280.)