In re Appeal of Springfield School District
101 A.3d 835
| Pa. Commw. Ct. | 2014Background
- VMDT purchased two adjoining commercial parcels in June 2011 for $11.4 million; parcels 487 and 7872 are in Springfield Township, Delaware County.
- 2012 and 2013 assessed values: parcel 487 $3,118,530; parcel 7872 $409,471; county CLRs were 67.5% (2012) and 72% (2013).
- School District appealed the 2012 assessments to the Board seeking base-year value of $11.4 million; Board denied the appeal; School District then appealed to trial court.
- VMDT counterclaimed that the 1998 base-year value should govern, arguing EPR vs. CLR methodology requires base-year valuation.
- Trial court rejected base-year approach, valued parcels using current market values and applied EPR/CLR per 8854(a)(2)-(3); uniformity challenge rejected.
- VMDT appeals, challenging the statutory framework and the District’s property-selection process for appeals.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether base-year valuation should govern on appeal | VMDT—base-year value should control | School District—base-year method not supported by law | No; current market value must be used on appeal |
| Whether the 1998 base-year valuation could be challenged after the 40-day period | Base-year valuation can be challenged on appeal | No timely challenge; 40-day window expired | Base-year challenge not timely; not preserved |
| Whether applying EPR/CLR to current value complies with uniformity | Uniformity requires base-year freeze to be scrutinized | EPR/CLR applied to current value; uniformity upheld | Yes; court properly applied EPR/CLR to current values; uniformity not violated |
| Whether School District’s property-selection for appeals violates Uniformity | Mooney’s threshold misused; lottery-like selection is discriminatory | Threshold rational to generate revenue; not discriminatory | Not discriminatory; threshold reasonable; uniformity not violated |
| Whether trial court’s weight of evidence supported current-value findings | VMDT’s appraiser credible; current values should reflect 1998 data | School District appraisers credible; current values appropriate | Yes; court’s credibility determinations supported by evidence |
Key Cases Cited
- Downingtown Area Sch. Dist v. Chester Cnty. Bd. of Assessment Appeals, 913 A.2d 194 (Pa. 2006) (uniformity and CLR/EPR concepts in uniform taxation)
- Clifton v. Allegheny Cnty., 969 A.2d 1197 (Pa. 2009) (uniformity requires proportional treatment across county valuations)
- Appeal of Armco, Inc., 515 A.2d 326 (Pa. Cmwlth. 1986) (administrative vs. review assessment methods; flexibility in testing base-year value)
- Daugherty v. Cnty. of Allegheny, 920 A.2d 936 (Pa. Cmwlth. 2007) (base-year method and current value on appeal; flexibility in assessment)
- Weissenberger v. Chester Cnty. Bd. of Assessment Appeals, 62 A.3d 501 (Pa. Cmwlth. 2013) (no deliberate discrimination in selective appeals; rational basis for threshold)
- Vees v. Carbon County Board of Assessment Appeals, 867 A.2d 742 (Pa. Cmwlth. 2005) (uniformity not violated by school district appeal policy)