Miller & Rhoads Bldg., L.L.C. v. City of Richmond, 790 S.E.2d 484

MRB bought the vacant Miller & Rhoads Building in 2006, located inside a City special service and assessment district and subject to both the citywide real estate tax and a special district tax calculated as a percentage of assessed value.
MRB rehabilitated the property and applied for Richmond’s Partial Exemption for Rehabilitated Real Estate (Richmond City Code §§ 98-149 to -159) to recoup rehabilitation costs.
The City applied the Partial Exemption to the base city real estate tax but refused to apply it to the special district tax; MRB paid the special district tax under protest and sued for correction/refund.
The parties stipulated the sole dispute: whether the Partial Exemption also applies to the City’s special district tax (Richmond City Code §§ 98-816 and 98-842).
The trial court held the Partial Exemption did not apply to the special district tax, reasoning the special district tax was not a “real estate tax” within the Partial Exemption’s meaning; the court entered a final order and MRB appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Richmond’s Partial Exemption for rehabilitated real estate applies to the City’s special district tax	MRB: the special district tax is a tax on real estate and therefore falls within the Partial Exemption’s plain text (applies to "real estate taxation")	City: special district tax is a different kind of real-estate-based charge and is not subject to the Partial Exemption; alternatively, §98-816 limits which Chapter 98 provisions apply to special district assessments	Court: affirmed trial court — Partial Exemption does not apply to the special district tax because §98-816 makes special district assessments subject only to enumerated levy/collection sections and omits the Partial Exemption (expressio unius)
Whether the trial court erred by relying on legislative purpose and origin rather than plain text	MRB: interpretation should follow plain statutory text — exemption applies to any real estate tax	City: purpose and practical differences support exclusion	Court: trial court erred in its purposive reasoning, but judgment stands under "right result for wrong reason" doctrine because the record supports the expressio unius statutory-ground adopted by the majority

CVAS 2, LLC v. City of Fredericksburg, 289 Va. 100 (statutory interpretation reviewed de novo)
Baker v. Commonwealth, 284 Va. 572 (use plain meaning unless ambiguous)
Haynes v. Haggerty, 291 Va. 301 ("right result for wrong reason" principle)
Perry v. Commonwealth, 280 Va. 572 (affirming judgment despite erroneous reasoning)
Virginia Dep’t of Health v. NRV Real Estate, LLC, 278 Va. 181 (application of expressio unius canon)
City of Richmond v. Richmond-Petersburg Turnpike Auth., 204 Va. 596 (determining whether a levy constitutes a real estate tax)