516 S.W.3d 830
Mo.2017Background
- Landowners own residential property entirely in St. Louis County that lies within several multi-county taxing districts (including St. Louis Community College District, Special School District of St. Louis County, Rockwood School District, and Eureka Fire Protection District).
- Landowners appealed their 2011–12 St. Louis County assessments, conceding assessments were accurate and uniform within St. Louis County, but alleging properties in Jefferson and Franklin Counties were systematically undervalued, forcing them to bear a disproportionate share of multi-county taxes.
- The St. Louis County Board of Equalization upheld the assessments; the State Tax Commission dismissed the appeals as beyond its authority on inter‑county equalization when reviewing a county board decision.
- Landowners sought administrative review (contested and non‑contested) and declaratory relief in circuit court, which dismissed the petition for failure to state a claim; the court of appeals transferred the case to the Missouri Supreme Court.
- The Supreme Court reviewed whether (1) the uniformity clause (Mo. Const. art. X, §3) supports a valuation‑based inter‑county claim and (2) the Commission had jurisdiction to perform inter‑county equalization on appeal from a county board.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the uniformity clause (art. X, §3) prohibits inter‑county valuation disparities in multi‑county taxing districts | Landowners: undervaluation in other counties makes taxes non‑uniform across the taxing district, so St. Louis must reduce its assessments to achieve uniformity | State/Commission: §3 requires uniformity of taxes (rates) within the taxing authority’s territorial limits; it does not regulate individual county valuations | Held: §3 addresses uniformity of taxes, not valuations; valuation‑based inter‑county claim fails |
| Whether Savage permits challenging inter‑county valuation disparities under §3 | Landowners: rely on Savage to show discriminatory assessments can violate uniformity | Commission: Savage addressed intra‑county discrimination/equal protection, not an inter‑county uniformity rule | Held: Savage dealt with intra‑county over/under‑assessment (equal protection), not §3‑based inter‑county valuation claims |
| Whether the County Board/Commission had jurisdiction to correct alleged inter‑county valuation disparities when hearing appeal from a county board | Landowners: Commission had a duty under art. X, §14 and statutes to equalize between counties and thus should remedy disparities on appeal | Commission/County Board: county boards handle intra‑county equalization; on appeals from a county board the Commission’s jurisdiction is derivative and limited to intra‑county issues | Held: Commission and county board lacked authority to perform inter‑county equalization on an appeal from a county board; dismissal proper |
| Whether declaratory/other relief was available to attack alleged inter‑county disparities | Landowners: sought declaratory relief (and other writs) asserting discriminatory assessments and Commission failure to equalize | State: such inter‑county equalization orders are not subject to collateral attack in a landowner’s county‑board appeal; petition fails to state a claim | Held: Declaratory judgment and related claims dismissed for failure to state a claim; judgment affirmed |
Key Cases Cited
- Alumax Foils, Inc. v. City of St. Louis, 939 S.W.2d 907 (Mo. banc 1997) (defining "revenue law of the state" and limits of exclusive appellate jurisdiction)
- Savage v. State Tax Comm’n of Mo., 722 S.W.2d 72 (Mo. banc 1986) (assessment discrimination within a county addressed under equal protection/statute, not a §3 inter‑county valuation rule)
- Foster Bros. Mfg. Co. v. State Tax Comm’n of Mo., 319 S.W.2d 590 (Mo. 1958) (county boards handle intra‑county equalization; Commission’s jurisdiction on appeal is derivative)
- Westwood P’ship v. Gogarty, 103 S.W.3d 152 (Mo. Ct. App. 2003) (Commission limited to intra‑county equalization when reviewing county board decisions)
- Bateman v. Rinehart, 391 S.W.3d 441 (Mo. banc 2013) (standard of review for Commission decisions on appeal)
- Anderson v. Union Elec. Co., 463 S.W.3d 783 (Mo. banc 2015) (de novo review of dismissal for failure to state a claim)