SAN FRANCISCO - Dozens of "cash-out refunding bonds" issued by California school districts were unconstitutional and illegal, according to an opinion published yesterday by Attorney General Jerry Brown.

Brown said that the bonds remain legal obligations of the school districts - which protects investors - because none of the deals were challenged during the 60-day validation period designated under state law. But he added that the districts may face lawsuits from taxpayers demanding to be compensated by school districts that over-taxed them.

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