Bill Furst, etc. v. Rod Rebholz, etc.

CourtSupreme Court of Florida
DecidedApril 6, 2023
DocketSC2020-1479
StatusPublished

This text of Bill Furst, etc. v. Rod Rebholz, etc. (Bill Furst, etc. v. Rod Rebholz, etc.) is published on Counsel Stack Legal Research, covering Supreme Court of Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bill Furst, etc. v. Rod Rebholz, etc., (Fla. 2023).

Opinion

Supreme Court of Florida ____________

No. SC2020-1479 ____________

BILL FURST, etc., et al., Petitioners,

vs.

ROD REBHOLZ, etc., et al., Respondents.

April 6, 2023

MUÑIZ, C.J.

This case is about the availability of the homestead tax

exemption to a property owner who lives in one part of a residential

structure but rents out another part for the exclusive use of a

tenant. See Furst v. Rebholz as Trustee of Rod Rebholz Revocable

Trust, 302 So. 3d 423 (Fla. 2d DCA 2020). We hold that the owner

is not entitled to a homestead tax exemption on the rented portion,

because that portion is not the owner’s residence.1

1. We have jurisdiction. See art. V, § 3(b)(3), Fla. Const. I.

The Florida Constitution governs homestead property in

several distinct ways: protecting it from forced sale by creditors;

restricting its alienation and devise; exempting it from certain ad

valorem taxes; and imposing a 3% cap on annual assessment

increases (through the Save Our Homes amendment). Art. X, § 4,

Fla. Const.; art. VII, §§ 4(d)(1)a., 6(a), Fla. Const. This case involves

the homestead tax exemption and the Save Our Homes assessment

increase cap. Those provisions are intertwined, because the 3%

assessment increase cap applies only to property that is entitled to

a homestead tax exemption. Art. VII, § 4(d), Fla. Const.; Zingale v.

Powell, 885 So. 2d 277, 284-85 (Fla. 2004).

The homestead tax exemption is set out in article VII, section

6(a) of the state constitution. In relevant part, it says: “Every

person who has the legal or equitable title to real estate and

maintains thereon the permanent residence of the owner, or

another legally or naturally dependent upon the owner, shall be

exempt from taxation thereon, [up to specified amounts].” So there

are two components to the homestead tax exemption: ownership

and residency. Ownership is not contested in this case. Instead, -2- the parties’ dispute turns on the residency requirement and its

application. The question is how to determine the scope of a

property owner’s residence for purposes of the homestead tax

exemption.

The property here is a two-story residential structure located

in Sarasota. In the decisions below, both the trial court and the

district court characterized the structure as a “single family” home.

For the tax years 2004 through 2013, county tax officials treated

the entire structure as homestead property, based on owner Rod

Rebholz’s initial homestead exemption application in 1996. Rebholz

owned the property and lived in a portion of the structure at all

relevant times. But it is undisputed that, for the entire time,

Rebholz rented a portion of the structure to at least one tenant.

Rebholz lived on the bottom floor, which consisted of a

kitchen, living area, and bathroom. The upper floor had a common

laundry area and four individual rooms, each with its own living

area and bathroom; some of the rooms had a kitchenette. Each

room was lockable from the outside. The front door entry to the

property had two doorbells, one for the bottom floor and the other

for the top. -3- The record includes testimony from John Michael Beaumont,

a tenant who rented one of the upstairs rooms without interruption

from 1996 through the tax years at issue (2004 to 2013) and

beyond. Beaumont learned of the property by reading an

advertisement in the newspaper. A written rental agreement

between Rebholz and Beaumont refers to the rate for Beaumont’s

“unit.” In his testimony, Beaumont called his unit “my place, my

room, my apartment.” Beaumont referred to Rebholz as “my

landlord.” Beaumont also spoke of “other tenants” and estimated

that, since 1996, eight to ten such persons had intermittently lived

in other rooms upstairs.

In 2014, the Sarasota County property appraiser became

aware that Rebholz might have received homestead benefits to

which he was not entitled. An investigation revealed the

configuration of the property and the rental situation just

described. Eventually, the property appraiser revoked the

homestead exemption on the 15% of the property that corresponded

to Beaumont’s unit, leaving intact the homestead exemption on the

remaining 85% of the property. The property appraiser reasoned

that, although Rebholz owned the entire structure and resided in -4- part of it, at least 15% of the property was not being used as

Rebholz’s residence. 2

When a property appraiser determines that a person has

improperly received a homestead tax exemption or Save Our Homes

benefit, Florida law requires the property appraiser to impose the

additional taxes that would have been due for up to the preceding

ten years, plus a penalty and interest. §§ 196.161(1)(b),

193.155(10), Fla. Stat., (2014).3 In Rebholz’s case, the revocation of

the homestead exemption as to 15% of the total property had the

effect of removing the Save Our Homes benefit from that limited

portion of Rebholz’s property. The property appraiser therefore

recalculated Rebholz’s taxes for tax years 2004 through 2013,

applying to the non-homestead portion a 10% annual assessment

increase cap (instead of the 3% Save Our Homes cap). The result

2. The underlying complaint in this case and the subsequent court decisions did not address the 15% calculation or the methodology behind it, but rather the authority of the property appraiser to make this apportionment at all. Our decision is similarly limited in scope.

3. In this opinion, we will cite the Florida Statutes as they existed in 2014. Between 2003 and 2014, the statutory provisions cited in this opinion were not changed in ways material to this case.

-5- was that Rebholz owed approximately $7,000 in back taxes,

penalties, and interest. He paid the tax lien but then sued the

property appraiser, the tax collector, and the state Department of

Revenue for a refund and a reinstatement of homestead status to

the entire property. 4

After a bench trial, the circuit court entered judgment in

Rebholz’s favor. The court concluded that the entire structure

should be considered Rebholz’s residence, and it held that “[m]erely

sharing the residence with a tenant does not create a classification

of property not exempted.” The court continued: “Florida law does

not authorize the Property Appraiser to deny a homeowner his

constitutional homestead exemption for a room rented within his

residence while he simultaneously maintains the property as his

permanent residence.”

On appeal, a divided panel of the Second District Court of

Appeal affirmed in relevant part. The district court echoed the trial

4. Rod Rebholz initiated this litigation but died on November 20, 2015. Donald Rebholz, as the successor trustee to the Rod Rebholz Revocable Trust, was substituted as the plaintiff and is the respondent in this case.

-6- court, holding that “the property appraisers of this state are not

authorized by law to carve up a homeowner’s permanent residence

in order to remove the protection provided by the constitutional

homestead exemption when that person rents a bedroom or any

other space within their home.” Furst, 302 So. 3d at 434. The

district court also held that Florida Administrative Code Rule 12D-

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Related

Zingale v. Powell
885 So. 2d 277 (Supreme Court of Florida, 2004)
Garcia v. Andonie
101 So. 3d 339 (Supreme Court of Florida, 2012)

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