Atlantic City Municipal Utilities Authority v. City of Absecon

CourtNew Jersey Tax Court
DecidedMay 10, 2021
Docket012518-2020
StatusUnpublished

This text of Atlantic City Municipal Utilities Authority v. City of Absecon (Atlantic City Municipal Utilities Authority v. City of Absecon) is published on Counsel Stack Legal Research, covering New Jersey Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Atlantic City Municipal Utilities Authority v. City of Absecon, (N.J. Super. Ct. 2021).

Opinion

NOT FOR PUBLICATION WITHOUT APPROVAL OF THE TAX COURT COMMITTEE ON OPINIONS

----------------------------------------------x ATLANTIC CITY MUNICIPAL : TAX COURT OF NEW JERSEY UTILITIES AUTHORITY, : DOCKET NO: 012518-2020 : 000441-2021 Plaintiff, : : v. : : CITY OF ABSECON, : CITY OF PLEASANTVILLE, : TOWNSHIP OF GALLOWAY, and : TOWNSHIP OF EGG HARBOR, : : Defendants. : ----------------------------------------------x

Decided: May 7, 2021

Daniel J. Gallagher for plaintiff.

Michael J. Coskey for defendants City of Absecon and City of Pleasantville (Parker McCay P.A., attorneys).

Thomas G. Smith for defendants Township of Egg Harbor and Township of Galloway.

CIMINO, J.T.C.

I. INTRODUCTION

Defendants, City of Absecon, City of Pleasantville, Township of Galloway

and Township of Egg Harbor, seek dismissal of plaintiff’s complaint for failure to

1 establish that the subject property is exempt pursuant to N.J.S.A. 40:14B-63.

N.J.S.A. 40:14B-63 was amended to include an exception to exempt status. With

the amendment, certain properties described in N.J.S.A. 54:4-3.3 are not subject to

the exemption. Due to plaintiff’s lands being used for the purpose and for the

protection of a public water supply as described in N.J.S.A. 54:4-3.3, defendant’s

motion to dismiss is granted.

II. STATEMENT OF FACTS Plaintiff, Atlantic City Municipal Utilities Authority (ACMUA), is the owner

of various parcels in the defendant municipalities, City of Absecon, City of

Pleasantville, Township of Galloway and Township of Egg Harbor. The ACMUA

parcels located in the municipalities were assessed and plaintiff made a claim for a

tax exemption on August 6, 2020 and October 27, 2020. Plaintiff’s exemption

application was denied by the local tax assessors for each of the defendant

municipalities. On November 16, 2020, plaintiff filed their complaint requesting a

judgment declaring defendants be enjoined from collecting tax for 2020 on these

parcels. Plaintiff asserts that the properties are exempt from taxation pursuant to

N.J.S.A. 40:14B-63 and that the stated properties have been improperly taxed for

many years. Plaintiff filed a second complaint for 2021 on January 25, 2021 seeking

the same relief as the prior complaint. Defendants, City of Absecon and City of

Pleasantville, filed a motion to dismiss plaintiff’s complaint arguing that the

2 complaint fails to establish that the subject properties are exempt pursuant to

N.J.S.A. 40:14B-63. Defendants, Township of Galloway and Township of Egg

Harbor, joined in the motion. Plaintiff argues in its opposition brief that the

ACMUA property does not fall within the exception from exempt status found in

N.J.S.A. 40:14B-63.

III. LEGAL ANALYSIS

The issue presented in defendants’ motion to dismiss the complaint for failure

to state a claim is whether plaintiff’s subject property is exempt from taxation

pursuant to N.J.S.A. 40:14B-63. R. 4:6-2(e) motions to dismiss for a complaint’s

failure to state a claim on which relief may be granted should only be granted in the

rarest instances. Printing Mart-Morristown v. Sharp Elecs. Corp., 116 N.J. 739, 772

(1989). The complaint must be searched in depth and with liberality to determine if

a cause of action can be gleaned even from an obscure statement in the complaint.

Id. at 746. Every reasonable inference is accorded to the plaintiff. Ibid.

Plaintiff asserts in its complaints that the ACMUA is an institution entitled to

exemption under N.J.S.A. 40:14B-63 and that the properties found in the defendant

municipalities are “used exclusively for the production and purification of water

which it supplies to the City of Atlantic City.” With this statement taken as true, the

3 court must determine if this type of property is exempt for the purposes of N.J.S.A.

40:14B-63. In order to do so, this requires an analysis of N.J.S.A. 40:14B-63.

In 1957, New Jersey enacted the Municipal Utilities Authorities Law. L. 1957,

c. 183. N.J.S.A. 40:14B-1 to -69. Initially, the law provided:

Every utility system and all other property of a municipal authority are hereby declared to be public property of a political subdivision of the State and devoted to an essential public and governmental function and purpose and shall be exempt from all taxes and special assessments of the State or any subdivision thereof.

[L. 1957, c. 183, § 63.]

There was originally no exception to the exemption from taxes. All municipal

authority property was exempt. However, on November 8, 1968, New Jersey

amended the Municipal Utilities Authorities Law. Specifically, the amendment was

to section 63. L. 1968, c. 328. The amended language added “other than lands

subject to assessment and taxation pursuant to Revised Statutes 54:4-3.3,” shall be

exempt. Ibid. In other words, while any improvements would be exempt, the land

subject to N.J.S.A. 54:4-3.3 would not. The statute now reads:

Every utility system and all other property of a municipal authority are hereby declared to be public property of a political subdivision of the State and devoted to an essential public and governmental function and purpose and, other than lands subject to assessment and taxation pursuant to Revised Statutes 54:4-3.3, shall be exempt

4 from all taxes and special assessments of the State or any subdivision thereof.

[N.J.S.A. 40:14B-63 (emphasis added to indicate 1968 amendment).]

The relevant language in N.J.S.A. 54:4-3.3 includes:

The lands of counties, municipalities, and other municipal and public agencies of this State used for the purpose and for the protection of a public water supply shall be subject to taxation by the respective taxing districts where situated, at the taxable value thereof, without regard to any buildings or other improvements thereon, in the same manner and to the same extent as the lands of private persons, but all other property so used shall be exempt from taxation.

[N.J.S.A. 54:4-3.3 (emphasis added).]

N.J.S.A. 40:14B-63 sets out the real property tax exemption for property used for

public and governmental functions which are held by municipal authorities. The

plain language of the statute also sets a limit on the extent of the exemption through

N.J.S.A. 54:4-3.3. Those types of lands not subject to the exemption in N.J.S.A.

40:14B-63 are lands held by municipal authorities for the purpose and protection of

a public water supply. See N.J.S.A. 54:4-3.3. These lands are subject to taxation by

the taxing district where the lands are situated. Plaintiff claims the requirements for

the tax exemption pursuant to N.J.S.A. 40:14B-63 are met. The stated use of the

land is for the production and purification of water. However, this use must not fall

5 under the definition in N.J.S.A. 54:4-3.3 in order for the property to qualify for the

exemption.

An earlier version of N.J.S.A. 54:4-3.3 helps guide the analysis. In 1910, a

supplement to an act entitled “An act for the assessment and collection of taxes” was

enacted. L. 1910, c. 118. This supplement contained the language now essentially

found in N.J.S.A. 54:4-3.3, “lands of the respective counties, townships, cities,

boroughs, towns and other municipal and public agencies of this State, used for the

purpose and for the protection of public water supply, shall be subject to taxation by

the respective taxing districts. . .” L. 1910, c. 118.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

In Re Appeal of the City of East Orange
246 A.2d 722 (New Jersey Superior Court App Division, 1968)
City of East Orange v. TP. OF LIVINGSTON
246 A.2d 178 (New Jersey Superior Court App Division, 1968)
City of Clifton v. N. JERSEY DIST. WATER SUP.
249 A.2d 14 (New Jersey Superior Court App Division, 1969)
Printing Mart-Morristown v. Sharp Electronics Corp.
563 A.2d 31 (Supreme Court of New Jersey, 1989)
The CITY OF EAST ORANGE v. Township of Livingston
253 A.2d 546 (Supreme Court of New Jersey, 1969)
City of Newark v. West Milford Tp., Passaic County
88 A.2d 211 (Supreme Court of New Jersey, 1952)
Mayor of Jersey City v. Blum
127 A. 214 (Supreme Court of New Jersey, 1925)
Mayor of Jersey City v. Blum
2 N.J. Misc. 188 (Supreme Court of New Jersey, 1924)
Morris County Municipal Utility Authority v. Morris Township
14 N.J. Tax 81 (New Jersey Tax Court, 1994)

Cite This Page — Counsel Stack

Bluebook (online)
Atlantic City Municipal Utilities Authority v. City of Absecon, Counsel Stack Legal Research, https://law.counselstack.com/opinion/atlantic-city-municipal-utilities-authority-v-city-of-absecon-njtaxct-2021.