Sonoran Peaks, LLC v. Maricopa County
236 Ariz. 399
Ariz. Ct. App.2015Background
- Sonoran Peaks, LLC and Wildcat Ridge, LLC (Taxpayers) appealed 2012 property valuation to the Arizona Tax Court, alleging the land should be valued as agricultural.
- Taxpayers signed conditional settlement agreements in Dec. 2012 with Maricopa County to value the land as agricultural for 2012 and 2013; Board of Supervisors approval was required and occurred in Jan. 2013.
- Arizona law requires all taxes for the year of an appeal be paid before they become delinquent; first-half 2012 payment was due Oct. 1 and delinquent Nov. 1; Taxpayers paid the first half late (Nov. 28).
- Taxpayers moved to enforce the settlement after learning of the late payment; the tax court denied enforcement and, because the statutory cure period in A.R.S. § 42-16210 was not met, dismissed the 2012 appeals for lack of timely payment.
- Taxpayers contend the court retained jurisdiction to enforce/interpret the settlement (or alternatively could not interpret it if jurisdiction was lost); the Court of Appeals reviewed jurisdiction and statutory interpretation de novo.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the tax court retained jurisdiction to enforce settlement despite Taxpayers' late 2012 payment | Taxpayers: court kept jurisdiction to enforce settlement under § 42-11004; settlement meant they were not testing tax validity so § 42-16210 did not apply | County: Chapter 16 (§ 42-16210) governs appeals and requires timely payment; settlement not effective until Board approval and did not alter statutory deadlines | Held: Court lacked jurisdiction because Taxpayers failed to timely pay under § 42-16210; dismissal was mandatory |
| Whether the tax court could interpret or enforce the settlement after losing jurisdiction | Taxpayers: if court lost jurisdiction over appeals, it still could construe/enforce settlement | County: once jurisdiction was lost the court could not adjudicate the settlement enforcement | Held: Court of Appeals declined to reach this issue because dismissal under § 42-16210 was proper; a court without jurisdiction cannot decide such matters |
Key Cases Cited
- Pima Cnty. v. Cyprus-Pima Mining Co., 119 Ariz. 111, 579 P.2d 1081 (Ariz. 1978) (taxpayer’s statutory appeal method is exclusive)
- Arizona Dep’t of Revenue v. Dougherty ex rel. Cnty. of Maricopa, 198 Ariz. 1, 6 P.3d 306 (App. 2000) (failure to follow statutory procedures divests tax court of jurisdiction)
- RCJ Corp. v. Ariz. Dep’t of Revenue, 168 Ariz. 328, 812 P.2d 1146 (Ariz. Tax Ct. 1991) (Chapter-specific statute controls in tax appeals)
- City of Bisbee v. Ariz. Water Co., 214 Ariz. 368, 153 P.3d 389 (App. 2007) (standard of review for jurisdictional and statutory interpretation questions)
- Freeport McMoRan Corp. v. Langley Eden Farms, LLC, 228 Ariz. 474, 268 P.3d 1131 (App. 2011) (courts should avoid deciding unnecessary or advisory issues)