Background

• McHenry Solar, LLC owns a solar facility in Hampton with equipment used to generate electricity sold to Connecticut Light & Power.
• Plaintiff challenges Hampton’s property tax on this equipment, seeking exemption under § 12-81(76) for machinery and equipment used in manufacturing.
• Plaintiff filed a motion for summary judgment alleging the property qualifies as manufacturing machinery under § 12-81(76).
• Trial court denied the motion on January 2, 2024, adopting the interpretation that generation of electricity is not manufacturing under the statute, citing Groppo and related history.
• The appellate court held that the trial court correctly denied summary judgment, relying on legislative history and statutory context; the case was remanded for further proceedings consistent with the opinion.

Issues

Key Cases Cited

• United Illuminating Co. v. Groppo, 220 Conn. 749 (Conn. 1992) (holding that electricity generation is not manufacturing for sales-tax exemptions informs property-tax exemption interpretation)
• Sikorsky Aircraft Corp. v. Commissioner of Revenue Services, 297 Conn. 540 (Conn. 2010) (analyzed manufacturing definitions pre/post-1992; upheld that broad 1992 definition did not include electricity generation for exemption scope)
• Rainbow Housing Corp. v. Cromwell, 340 Conn. 501 (Conn. 2021) (emphasizes avoiding absurd results and respecting legislative intent in statutory exemptions)
• Wind Colebrook South, LLC v. Colebrook, 344 Conn. 150 (Conn. 2022) (concurrence reaffirming Groppo’s relevance to electricity-generation exemptions)
• Connecticut Water Co. v. Barbato, 206 Conn. 337 (Conn. 1988) (cited in framework for applying prior statutory interpretations to current exemptions)