Does the doctrine of exhaustion of administrative remedies apply to constitutional challenges of zoning ordinances?

It is well settled law in California that the doctrine of exhaustion of administrative remedies applies to constitutional challenges of zoning ordinances. In Metcalf v. County of Los Angeles (1944) 24 Cal.2d 267, 148 P.2d 645, it was ruled that in a constitutional challenge of an ordinance as applied to a specific parcel of property, the party challenging the act must first apply to the zoning authority for an exception or variance as provided under the ordinance. In the case of Igna v. Baldwin Park (1970) 9 Cal.App.3d 909, 88 Cal.Rptr. 581, an owner of three trailer parks constitutionally challenged a comprehensive zoning ordinance which required the owner to apply for a conditional use permit [77 Cal.App.3d 94] because a trailer park was nonconforming activity in the new zone. Appellant owner had not applied for a conditional use permit. The court held that such a challenge to the ordinance must be preceded by an application to the city for a conditional use permit. The main thrust of the challenge was that the ordinance was invalid as it applied to the specific properties, not that it was invalid in general. (Id., at p. 913, 88 Cal.Rptr. 581.)