Columbus Board of Tax Assessors v. Medical Center Hospital Authority, 302 Ga. 358

In 2004 Columbus Regional (a private nonprofit) leased land to the Medical Center Hospital Authority (Hospital Authority) to develop Spring Harbor, a continuing-care retirement facility; improvements would revert to Columbus Regional at lease end.
The Hospital Authority issued revenue bonds to finance construction and entered a management agreement with a Columbus Regional affiliate to build, manage, and operate the facility.
Superior court validated the bonds in 2004 and again in 2007; the 2007 validation found the project served a public purpose but also made findings that Columbus Regional and its affiliates effectively built, owned, managed, and controlled Spring Harbor.
The Columbus Board of Tax Assessors billed the Hospital Authority for ad valorem taxes on the improvements; the Hospital Authority sued, claiming its leasehold interest was "public property" exempt under OCGA § 48-5-41(a)(1)(A).
The trial court granted summary judgment for the Hospital Authority, relying on the bond validation orders as conclusive proof of ownership/public purpose; the Court of Appeals affirmed.
The Georgia Supreme Court granted certiorari, held that bond-validation judgments are conclusive only as to matters actually adjudicated in those proceedings and do not conclusively determine tax-exempt status here, and reversed and remanded for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the 2004 and 2007 bond-validation orders conclusively establish that the Hospital Authority's leasehold interest is "public property" exempt from ad valorem taxation	Bond validations conclusively found the bonds and project served a public purpose and confirmed the Authority's property interest; thus the leasehold is tax-exempt public property	Bond validations did not decide taxation; factual findings show private ownership/control and the validations did not adjudicate tax-exempt status, so the leasehold may be taxable	The bond-validation orders did not conclusively establish tax-exempt "public property" status; the question of exemption must be determined under established public-property tests and was remanded for further proceedings

Sigman v. Brunswick Port Auth., 214 Ga. 332 (explaining "public property" requires ownership for benefit of state/public)
Hosp. Auth. of Albany v. Stewart, 226 Ga. 530 (setting standard for when an authority's holdings qualify as public property vs. private gain)
Delta Air Lines, Inc. v. Coleman, 219 Ga. 12 (leasehold can be severed from fee and taxed separately; public exemption lasts only while property remains in public ownership)
Sherman v. Fulton County Bd. of Assessors, 288 Ga. 88 (bond-validation judgments are conclusive only as to matters actually referenced and adjudicated in those proceedings)
Columbus, Ga. Bd. of Tax Assessors v. Med. Ctr. Hosp. Auth., 338 Ga. App. 302 (Court of Appeals decision affirming trial court based on bond validations; reviewed and reversed)