ADKINS, Judge.
The respondents in this appeal, Halle Development, Inc., et al., are representative plaintiffs in a class action of current property owners ("the Owners") that seek to recover development impact fees collected by Anne Arundel County, Maryland ("the County"), petitioner, for the fiscal years 1988 through 1996. The Circuit Court determined that because (1) $4,719,359 in impact fees
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