Armstrong-Trotwood, LLC v. State Tax Commission of Missouri, ED104000

Seven landowners owning property in St. Louis County (within several multi‑county taxing districts) challenged their 2011–2012 assessments as discriminatory because properties in neighboring counties in the same taxing districts were allegedly undervalued.
Landowners appealed to the St. Louis County Board of Equalization (BOE); BOE sustained the assessments and Landowners appealed to the State Tax Commission (STC).
STC (via hearing officer) dismissed the consolidated appeals for lack of jurisdiction, reasoning that issues of inter‑county equalization fall outside the BOE’s (and thus the STC’s) authority because Article X, § 3 uniformity is limited to county boundaries.
Landowners sued in St. Louis County Circuit Court raising judicial‑review, declaratory‑judgment, mandamus, and certiorari claims; the circuit court dismissed the petition for failure to state a claim.
On appeal, the court concluded the dispositive question requires construction of Missouri revenue laws (Article X §§ 3 and 14 and RSMo § 138.380) — specifically the meaning of “authority levying the tax” for multi‑county taxing jurisdictions — and therefore the case must be transferred to the Missouri Supreme Court under Article V, § 11.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Meaning of “authority levying the tax” in Article X, § 3 for multi‑county tax districts	Uniformity must be measured across the whole multi‑county taxing district (school/fire districts), not by county	The taxing authority is the county (territorial limits = county), so uniformity is measured within each county	Court held this construction question involves state revenue laws and is beyond the court of appeals’ jurisdiction; transfer to Mo. Supreme Court required
STC jurisdiction to decide inter‑county equalization on BOE appeals	STC had duty to equalize valuations across counties and thus must hear inter‑county equalization claims on appeal	STC and BOE lack authority over inter‑county equalization in BOE appeals because BOE’s jurisdiction is county‑limited	Court declined to resolve on merits, finding resolution requires construction of revenue laws reserved to the Supreme Court
Whether the revenue‑law construction issue can be resolved by existing Supreme Court precedent	Landowners: no controlling Supreme Court interpretation exists for multi‑county districts; this is a novel question	Respondents cited appellate decisions and dicta but no definitive Supreme Court construction	Court found no Supreme Court precedent addressing this precise question; thus transfer required

Twelve Oaks Motor Inn v. Strahan, 96 S.W.3d 106 (Mo. App. S.D.) (discusses Supreme Court exclusive jurisdiction over revenue law construction)
ABB C-E Nuclear Power, Inc. v. Dir. of Revenue, 215 S.W.3d 85 (Mo. banc) (transferred appellate case to Supreme Court under Article V § 11)
Alumax Foils v. City of St. Louis, 939 S.W.2d 907 (Mo. banc) (defines "revenue law" and its application)
Hermel, Inc. v. State Tax Comm'n, 564 S.W.2d 888 (Mo. banc) (defines "construction" of a law)
May Dep't Stores Co. v. State Tax Comm'n, 308 S.W.2d 748 (Mo.) (states inter‑county equalization issues concern construction of revenue laws)
Foster Bros. Mfg. Co. v. State Tax Comm'n, 319 S.W.2d 590 (Mo.) (same principle regarding inter‑county equalization)