Cite as: 513 U. S. 106 (1994)
Opinion of the Court
damus notwithstanding. Id., at 456. For good measure, the Court also looked at prior Alabama law on mandamus and found nothing "suggest[ing] that mandamus is the exclusive remedy" in this situation. Id., at 457 (emphasis in original). Justice Harlan thus concluded: "Novelty in procedural requirements cannot be permitted to thwart review in this Court applied for by those who, in justified reliance upon prior decisions, seek vindication in state courts of their federal constitutional rights." Id., at 457-458, citing Brinkerhoff-Faris Trust & Sav. Co. v. Hill, 281 U. S. 673 (1930) (due process violated when state court denied injunction against collection of unlawful taxes on the basis of taxpayer's failure to pursue administrative remedies, where State's prior "settled" law made clear that no such administrative remedies existed); see generally Meltzer, State Court Forfeitures of Federal Rights, 99 Harv. L. Rev. 1128, 1137- 1139 (1986).
Finally, Georgia contends that Reich had no idea (before Davis) that the taxes he was paying throughout the 1980's might be unconstitutional. Even assuming Reich had no idea, however, we are not sure we understand the argument. If the argument is that Reich would not have taken advantage of the State's predeprivation remedies no matter how adequate they were (and thus has no standing to complain of those remedies), the argument is beside the point for the same reason that we said that the Georgia Supreme Court's reliance on those remedies was beside the point: Reich was entitled to pursue what appeared to be a "clear and certain" postdeprivation remedy, regardless of the State's predeprivation remedies. Alternatively, if the argument is that Reich needed to have known of the unconstitutionality of his taxes in order to pursue the State's postdeprivation remedy, the argument is wrong. It is wrong because Georgia's re-fund statute has a relatively lengthy statute of limitations period, and, at least until this case, see Reich I, 262 Ga., at 629, 422 S. E. 2d, at 849, contained no contemporaneous pro-
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