Campelli v. Mansfield, SC21209

The plaintiffs’ Mansfield property was classified as forest land in 2005 based on a certified forester’s report stating it was a single twenty-five acre tract, but a 2021 review revealed it was actually 22.53 acres. 1
The assessor then treated the property as still qualifying only because the plaintiffs also owned a 14.05 acre Tolland parcel, and the combined acreage met the twenty-five acre requirement. 2
After the plaintiffs sold the Tolland parcel, the assessor terminated the Mansfield property’s forest land classification and increased its assessed value. 3
The trial court held the Mansfield property had been misclassified from the start but could not be declassified under §12-504h because it had not been sold and its use had not changed. 4
On appeal, the town argued its assessor could terminate the classification under §§12-504h, 12-107d, or 12-55 because the property never met the statutory acreage requirement. 5
The Supreme Court affirmed, holding municipal assessors lack statutory authority to terminate erroneous forest land classifications and such challenges must be directed to the state forester. 6

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did sale of Tolland parcel authorize declassification under §12-504h? 7	Mansfield parcel itself was never sold or transferred.	Selling Tolland left plaintiffs under twenty-five acres.	No; 'such land' meant the Mansfield parcel, which was not sold. 8
Could assessor correct an erroneous forest land classification under §12-107d? 9	Only the state forester may review acreage errors.	Assessor could terminate because classification was wrong from inception.	No; assessor lacked authority and errors must go to the state forester. 10
Did §12-55 allow declassification to equalize assessments? 11	Specific forest-land statutes control over general assessment power.	§12-55 let assessor correct the mistaken classification.	No; §12-55 does not authorize termination of land classifications. 12

Carmel Hollow Associates Ltd. Partnership v. Bethlehem, 269 Conn. 120 (2004) (municipal assessors lack authority to terminate erroneous forest land classifications 13)
Griswold Airport, Inc. v. Madison, 289 Conn. 723 (2008) (§12-55 does not authorize assessors to terminate land classifications 14)
Timber Trails Associates v. New Fairfield, 226 Conn. 407 (1993) (cited for plaintiffs’ position on assessor authority 15)
Rustici v. Stonington, 174 Conn. 10 (1977) (forest land statutes provide preferential tax treatment to encourage conservation 16)
Trinity Christian School v. Commission on Human Rights & Opportunities, 329 Conn. 684 (2018) (courts do not rewrite statutes under the guise of interpretation 17)
PPC Realty, LLC v. Hartford, 350 Conn. 347 (2024) (legislature must remedy perceived inconsistencies in the statutory scheme 18)