Bolton v. Town of Scarborough

CourtSuperior Court of Maine
DecidedFebruary 16, 2015
DocketCUMcv-14-59
StatusUnpublished

This text of Bolton v. Town of Scarborough (Bolton v. Town of Scarborough) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bolton v. Town of Scarborough, (Me. Super. Ct. 2015).

Opinion

STATE OF MAINE BUSINESS AND CONSUMER COURT

Cumberland, ss.

ANGELL FAMILY 2012 PROUTS NECK TRUST et als.,

Plaintiffs-Appellants,

v. Docket No. BCD-CV-14-59 /

TOWN OF SCARBOROUGH et al., 4tV1H-CUWI- 0#.-t$-15 Defendants-Appellees

KENYON C. BOLTON, III, et als.,

v. Docket No. BCD-CV-14-59

TOWN OF SCARBOROUGH et al.

Defendants-Appellants

DECISION AND JUDGMENT

Pursuant to M.R. Civ. P. BOB, the Appellants in these consolidated cases 1 appeal the

decision of the Town of Scarborough Board of Assessment Review ("Board"), denying

Appellants' requests for tax abatements, following the Town's 2012 partial property tax

revaluation of some, but not all, waterfront and water-influenced properties in Scarborough.

Appellants in their Joint Rule soB Brief argue the Board's decision must be reversed for

four reasons:

1) The Assessor selectively targeted waterfront property in three neighborhoods for a substantial increase in valuation, while allowing waterfront property in a

1 The cases had separate docket numbers in the Superior Court but had been consolidated by the time they were transferred to the Business and Consumer Court, and were assigned a single BCD docket number.

1 similarly situated neighborhood (Piper Shores) to avoid any increase in valuation.

2) The Assessor arbitrarily exempted certain waterfront properties from the increase in valuation.

3) The Assessor gave huge tax breaks to "excess land" properties, impermissible under Maine law.

4) The Assessor's increase in valuation at Prouts Neck was based on unqualified sales.

Appellants' Joint Rule soB Brief at 5.

For the reasons set forth below, the court affirms the Board's decision, denies the appeal,

and grants judgment to the Appellees.

I. FACTUALBACKGROUND

Appellant taxpayers own properties on or near the Atlantic Ocean, in the Prouts Neck

neighborhood of Scarborough. (R. 2.) In 2012, after analyzing sales data, Scarborough

Assessor Paul Lesperance increased the assessment of properties in the Prouts Neck

neighborhood by 14.3 percent. (R. 647-50.) The assessed value of other properties in the Town

of Scarborough decreased or remained the same. Before 2012, the last town-wide revaluation

took place in 2005. (R. 5SS.) Appellants appealed the increased assessments on their properties

to the Board, which consolidated the appeals, held hearings, and unanimously denied the

appeals. (R. 6.)

II. STANDARDS OF REVIEW

1. Rule soB

In a Rule SOB appeal, the Superior Court reviews the findings made by the municipal

decision maker to determine whether those findings were based upon an "erroneous

interpretation of the law" or based upon conclusions of fact not "supported by substantial

evidence on the record as a whole." Bruk v. Town ofGeorgetown, 436 A.2d S94, S97 (Me. 19S1).

2 "Substantial evidence is evidence that a reasonable mind would accept as sufficient to support a

conclusion." York v. Town qf'Ogunquit, 2001 ME 53, ~ 6, 769 A.2d 172 (quoting Sproul v. Town

qf Boothbay Harbor, 2000 ME 30, ~ 6, 746 A.2d 368). "The Court must affirm the decision of

the [Board] unless that decision was unlawful, arbitrary, capricious, or unreasonable." Driscoll

v. Gheewalla, 441 A.2d 1025, 1026 (Me. 1982). Procedural unfairness is reversible error and a

"decision can be 'arbitrary and capricious' if it was not the product of the requisite processes."

Hopkins v. Dep't qfHuman Servs., 2002 ME 129, ~ 12, 802 A.2d 999 (citations omitted). "That

the record contains evidence inconsistent with the result, or that inconsistent conclusions could

be drawn from the evidence, does not render the [Board's] findings invalid if a reasonable mind

might accept the relevant evidence as adequate to support the [Board's] conclusion." Town qf

Vienna v. Kokernak, 612 A.2d 870, 872 (Me. 1992). The party seeking to overturn the decision

bears the burden of persuasion on appeal. Town qf Sw. Harbor v. Harwood, 2000 ME 213, ~ 6,

763 A.2d 115 (citing Sau;yer Envtl. Recovery Facilities, Inc. v. Town if Hampden, 2000 ME 179, ~

13, 760 A.2d 257).

2. Municipal Tax Assessments

With respect to judicial review of municipal tax assessments specifically, a court

presumes tax assessments are valid. Ram's Head Partners, LLC v. Town qfCape Elizabeth, 2003

ME 131, ~ 9, 834 A.2d 916. "A taxpayer who seeks a tax abatement must prove that the

assessed valuation is 'manifestly wrong."' Teifloth v. Town qf Scarborough, 2014 ME 57, ~ 12,

90 A.3d 1131. A taxpayer can prove an assessment is manifestly wrong by showing:

1) the judgment of the assessor was irrational or so unreasonable in light of the circumstances that the property was substantially overvalued and an injustice resulted;

2) there was unjust discrimination; or

3) the assessment was fraudulent, dishonest, or illegal.

3 Yusem v. Town of Raymond, 2001 ME 61, ~ 9, 769 A.2d 865.

"The constitutional requirement [for tax assessments] is the seasonable attainment of

a rough equality in tax treatment of similarly situated property owners." 2 Ram's Head Partners,

LLC v. Town ofCape Elizabeth, 200S ME lSI, ~ 10, 8S4 A.2d 916. "Neither the constitution

nor the statutes expect that a Board of Assessors could make an assessment with all values so

exact that no 'expert' could disagree with them." Sears, Roebuck & Co. v. Inhabitants of City of

Presque Isle, 150 Me. 181, 189, 107 A.2d 475, 480 (1954). Appellants in this case contend that

the Town's assessment was manifestly wrong in that it unjustly discriminated against owners

of waterfront and water-influenced properties. As mentioned above, the court will vacate the

Board's decision denying tax abatement "only if the record compels a contrary conclusion to

the exclusion of any other inference." Terfloth v. Town of Scarborough, 2014 ME 57, ~ IS, 90

A.sd liS 1.

"Taxpayers can prove discrimination only if they show that the assessor's system

necessarily results in unequal apportionment." Ram's Head, 200S ME lSI,~ IO, 8S4 A.2d 9I6

(citing City of Biddeford v. Adams, I999 ME 49, ~ I4, 727 A.2d S46.) "The undervaluation of

one set of similarly situated properties can support a finding of unjust discrimination, even

when there is no undervaluation of the general mass of property." Id. ~ II. On the other

hand, "some specific instances here and there" of undervaluation, "[s]poradic differences in

valuations," or "mere errors of judgment on the part of the assessors" do not necessarily

establish unjust discrimination. Id. (citing Kittery Elec. Light Co., 219 A.2d 728, 740 (Me. 1966);

Sunday Lake Iron Co. v. Township of Wakefield, 247 U.S. S50, S5S (1918) ("[M]ere errors of

2 Article IX Section 8 of the Constitution of the State of Maine reads as follows:

All taxes upon real and personal estate, assessed by authority of this state, shall be apportioned and assessed equally, according to the just value thereof ...

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

Related

Frank v. Assessors of Skowhegan
329 A.2d 167 (Supreme Judicial Court of Maine, 1974)
Buck v. Town of Yarmouth
402 A.2d 860 (Supreme Judicial Court of Maine, 1979)
Common Cause v. State
455 A.2d 1 (Supreme Judicial Court of Maine, 1983)
Blodgett v. School Administrative District 73
289 A.2d 407 (Supreme Judicial Court of Maine, 1972)
Sawyer Environmental Recovery Facilities, Inc. v. Town of Hampden
2000 ME 179 (Supreme Judicial Court of Maine, 2000)
Kittery Electric Light Co. v. Assessors of Kittery
219 A.2d 728 (Supreme Judicial Court of Maine, 1966)
City of Biddeford v. Adams
1999 ME 49 (Supreme Judicial Court of Maine, 1999)
Cohen v. Ketchum
344 A.2d 387 (Supreme Judicial Court of Maine, 1975)
Von Tiling v. City of Portland
268 A.2d 888 (Supreme Judicial Court of Maine, 1970)
McCorkle v. Town of Falmouth
529 A.2d 337 (Supreme Judicial Court of Maine, 1987)
Moser v. Town of Phippsburg
553 A.2d 1249 (Supreme Judicial Court of Maine, 1989)
Town of Vienna v. Kokernak
612 A.2d 870 (Supreme Judicial Court of Maine, 1992)
Town of Southwest Harbor v. Harwood
2000 ME 213 (Supreme Judicial Court of Maine, 2000)
Weekley v. Town of Scarborough
676 A.2d 932 (Supreme Judicial Court of Maine, 1996)
Sears, Roebuck & Co. v. Inhabitants of Presque Isle
107 A.2d 475 (Supreme Judicial Court of Maine, 1954)
Wells v. Portland Yacht Club
2001 ME 20 (Supreme Judicial Court of Maine, 2001)
Sproul v. Town of Boothbay Harbor
2000 ME 30 (Supreme Judicial Court of Maine, 2000)
Shawmut Inn v. Inhabitants of Kennebunkport
428 A.2d 384 (Supreme Judicial Court of Maine, 1981)
LaFleur Ex Rel. Anderson v. Frost
80 A.2d 407 (Supreme Judicial Court of Maine, 1951)

Cite This Page — Counsel Stack

Bluebook (online)
Bolton v. Town of Scarborough, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bolton-v-town-of-scarborough-mesuperct-2015.