331 Conn. 745
Conn.2019Background
- Groton conducted a townwide mass revaluation for the 2011 grand list using Tyler Technologies (Tyler) and assessor Mary Gardner; data collection included exterior inspections, mailers, and CAMA modeling.
- Groton Long Point (GLP) is a distinct planned neighborhood (~600 parcels) with private amenities; GLP improvement values had previously used a 1.2 adjustment from the 2006 revaluation.
- Preliminary ratio testing using validated sales (18 GLP sales) produced a median assessment-to-sales ratio (ASR) of ~88.3% using the 1.2 factor; Tyler and the town applied a 1.35 adjustment to dwelling values to achieve a median ASR ~92%.
- Plaintiffs (class of GLP homeowners) sued under Conn. Gen. Stat. § 12-119, arguing the uniform 35% increase via an undifferentiated adjustment factor violated statutory/regulatory requirements and produced manifestly excessive assessments.
- Trial court credited Tyler’s and Gardner’s testimony that the adjustment was a direct equalization to correct undervaluation, found the methodology lawful under OPM regulations and appraisal standards, and entered judgment for the town.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether assessor may apply a uniform adjustment factor to a neighborhood during mass appraisal | The 1.35 factor unlawfully applied a flat percentage to all GLP dwellings without individualized consideration, echoing Chamber of Commerce v. Waterbury | Adjustment factor was a permissible direct equalization based on neighborhood ratio study, consistent with OPM regs and mass appraisal standards | Court held application to neighborhood strata during mass appraisal is lawful; not illegal under § 12-119 |
| Whether § 12-62i-3 (ratio testing) permits neighborhood-level ratio testing/adjustments during appraisal | § 12-62i-3 contemplates only class-level (residential/commercial/vacant) testing and only as verification, not as a basis to set values | Regulation does not expressly prohibit neighborhood-level testing; other regs and CAMA requirements contemplate neighborhood outputs; adding a prohibition would read language into the rule | Court held regs do not preclude neighborhood stratification or using ratio studies/adjustments during the mass appraisal process |
| Whether use of ratio studies and direct equalization conforms to accepted appraisal standards | Plaintiffs argue methodology was arbitrary and not tied to true value; reliance on neighborhood sales was insufficient | Defendants cite Uniform Standards of Professional Appraisal Practice and IAAO standards endorsing ratio studies, stratification, and direct equalization as accepted mass appraisal tools | Court held use of ratio studies and direct equalization at neighborhood level is supported by professional appraisal standards |
| Whether plaintiffs proved manifestly excessive or illegal assessment under § 12-119 | Plaintiffs presented some sales trends suggesting price declines and argued the 35% increase caused overvaluation | Defendants showed compliance with regs, calibration, and lack of evidence of misfeasance or that values were manifestly excessive | Court held plaintiffs failed to show misfeasance or manifest overvaluation; § 12-119 relief unavailable |
Key Cases Cited
- Chamber of Commerce of Greater Waterbury, Inc. v. Waterbury, 184 Conn. 333 (Conn. 1981) (rejecting across-the-board percentage increases applied without adequate basis)
- Redding Life Care, LLC v. Redding, 308 Conn. 87 (Conn. 2013) (insufficiency of data or method alone does not show illegality under § 12-119 absent misfeasance)
- Walgreen Eastern Co. v. West Hartford, 329 Conn. 484 (Conn. 2018) (§ 12-119 requires proof of illegal assessment and manifest excessiveness; mere overvaluation insufficient)
- Second Stone Ridge Cooperative Corp. v. Bridgeport, 220 Conn. 335 (Conn. 1991) (distinguishes § 12-119 relief from administrative appeals and explains the extraordinary showing required)
- Griswold Airport, Inc. v. Madison, 289 Conn. 723 (Conn. 2008) (plenary review of legal issues in tax appeals and discussion of § 12-119 focus on illegality)