A. Thomas Jones brought a class action claiming that Atlanta water-system franchise and payment-in-lieu-of-tax charges were illegal taxes and seeking refunds. After Jones pursued administrative review, the superior court dismissed for lack of jurisdiction because he had not filed suit within 30 days of the appeals-board decision and alternatively entered judgment on the pleadings. The Court of Appeals of Georgia held that the refund statute did not impose that 30-day deadline and that the superior court therefore had jurisdiction. The court rejected the City’s argument that an administrative certiorari deadline applied, noting that the statute contained no such requirement and had previously used an express limitations period. It reversed the jurisdictional ruling, vacated the judgment on the pleadings and related ruling, and remanded for reconsideration.