Campelli v. Mansfield

Supreme Court of Connecticut·Decided July 21, 2026·No. SC21209·Published

Opinion

************************************************ The “officially released” date that appears near the beginning of an opinion is the date the opinion will be published in the Connecticut Law Journal or the date it is released as a slip opinion. The operative date for the beginning of all time periods for the filing of postopinion motions and petitions for certification is the “officially released” date appearing in the opinion. All opinions are subject to modification and technical correction prior to official publication in the Connecti- cut Law Journal and subsequently in the Connecticut Reports or Connecticut Appellate Reports. In the event of discrepancies between the advance release version of an opinion and the version appearing in the Connecticut Law Journal and subsequently in the Connecticut Reports or Connecticut Appellate Reports, the latest version is to be considered authoritative. The syllabus and procedural history accompanying an opinion that appear in the Connecticut Law Journal and subsequently in the Connecticut Reports or Connecticut Appellate Reports are copyrighted by the Secretary of the State, State of Connecticut, and may not be reproduced or distributed without the express written permission of the Commission on Official Legal Publications, Judicial Branch, State of Connecticut. ************************************************ Campelli v. Mansfield

MARIO CAMPELLI ET AL. v. TOWN OF MANSFIELD (SC 21209) Mullins, C. J., and McDonald, D’Auria, Ecker, Alexander, Dannehy and Bright, Js.

Syllabus

Pursuant to statute (§ 12-107b (2)), “forest land” is defined in relevant part as a tract or tracts of land in a municipality or municipalities “aggregating twenty-five acres or more in area bearing tree growth that conforms to . . . [certain] standards established by the State Forester . . . .”

Pursuant further to statute (§ 12-107d (f)), a property owner who has obtained a report from a certified forester certifying that the property owner’s land conforms to the standards established by the state forester may file an application with the assessor of the town in which the land is located, along with the certified forester’s report, to have the assessor classify the land as forest land and thereby receive a reduction in the property tax assessment, and, if the assessor determines that the use of the land as forest land has not changed as of or prior to the assessment date, the assessor shall classify the land as forest land.

Pursuant further to statute (§ 12-504h), land that has been classified as for- est land “shall remain so classified without the filing of any new application subsequent to such classification . . . until either . . . [t]he use of such land is changed to a use other than that described in the application for the existing classification . . . or . . . such land is sold or transferred . . . .”

The plaintiffs, who owned property located in the town of Mansfield, appealed to the Superior Court from the decision of the defendant town’s board of assessment appeals, which had upheld the decision of the town assessor to terminate the property’s classification as forest land. In 2005, the plaintiffs had submitted to the assessor an application, seeking to have their Mans- field property classified as forest land for municipal property tax purposes under § 12-107b (2) (A), along with a report by a certified forester attesting that their property met the criteria for forest land classification under that provision because it was a single 25 acre tract of land that conformed to the relevant standards. The assessor had approved the application, but, in 2021, the assessor discovered that the property was actually 22.53 acres. The assessor notified the plaintiffs that the property therefore did not qualify as forest land under § 12-107b (2) (A), but the assessor nonetheless indicated that the property continued to qualify as forest land under § 12-107b (2) (B) because the plaintiffs also owned a 14.05 acre parcel in the town of Tolland that also was classified as forest land, and, when the two properties were aggregated, they satisfied the statute’s 25 acre requirement. When the plaintiffs subsequently sold the 14.05 acre Tolland parcel, the assessor terminated the classification of the plaintiffs’ Mansfield property as forest Campelli v. Mansfield

land, causing the property’s assessed value to increase substantially. The trial court ultimately sustained the plaintiffs’ appeal from the board’s deci- sion, concluding that, although the Mansfield property had been erroneously designated as forest land because it was not and never had been 25 or more acres, § 12-504 did not permit the assessor to terminate the property’s forest land classification because the property had not been sold and its use had not changed. The trial court therefore ordered the town to reinstate the forest land classification of the Mansfield property and to assess property taxes on the property accordingly. On appeal, the town claimed that its assessor had the statutory authority to terminate the property’s classification as forest land because that property had never satisfied the minimum acreage requirement of § 12-107b (2). Held:

The trial court properly sustained the plaintiffs’ appeal from the board’s decision upholding the assessor’s declassification of the property as forest land and ordered the town to reinstate the forest land classification of the property, this court having concluded that municipal assessors lack the statutory authority to terminate erroneous forest land classifications and that such claims must be directed to the state forester.

The town could not prevail on its claim that its assessor had the authority to terminate the forest land classification of the Mansfield property pursuant to § 12-504h (2) on the ground that “such land [was] sold or transferred by” the plaintiffs when they sold their Tolland parcel.

The term “such land,” as used in § 12-504h (2), plainly and unambiguously referred back to the “land” previously specified in the text of that statute, that is, the “land” described in a property owner’s application for forest land classification.

The only land described in the plaintiffs’ application to the town for forest land classification was the Mansfield property, that property was classified as forest land under § 12-107b (2) (A) as a single 25 acre tract, independent of the 14.05 acre Tolland parcel, and, because the Mansfield property was not sold or transferred and its use had not changed to a use other than that described in the plaintiffs’ application to classify the Mansfield property as forest land, the sale of the Tolland parcel had no effect on the forest land classification of the Mansfield property, and the assessor was not authorized under § 12-504h (2) to declassify the Mansfield property as forest land.

The town could not prevail on its claim that its assessor had the authority to terminate the Mansfield property’s forest land classification under § 12-107d (f) insofar as that classification was erroneous from its inception on the basis that the Mansfield property never satisfied the minimum twenty-five acre requirement of § 12-107b (2).

This court previously held, under an earlier version of § 12-107d, that munici- pal assessors lack statutory authority to terminate forest land classifications, even if those classifications are erroneous, on the basis that the earlier ver- sion of the statute provided that an assessor “shall” approve an application for the classification of property as forest land if the property has been so Campelli v. Mansfield

designated by the state forester and that there was no statutory provision that gave an assessor discretionary authority to deny such an application under those circumstances.

Moreover, subsequent legislation (P.A.

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