Gourmet Dining, LLC v. Union Township (083146)(Tax Court & Statewide)

CourtSupreme Court of New Jersey
DecidedJune 30, 2020
DocketA-8-19
StatusPublished

This text of Gourmet Dining, LLC v. Union Township (083146)(Tax Court & Statewide) (Gourmet Dining, LLC v. Union Township (083146)(Tax Court & Statewide)) is published on Counsel Stack Legal Research, covering Supreme Court of New Jersey primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gourmet Dining, LLC v. Union Township (083146)(Tax Court & Statewide), (N.J. 2020).

Opinion

SYLLABUS

This syllabus is not part of the Court’s opinion. It has been prepared by the Office of the Clerk for the convenience of the reader. It has been neither reviewed nor approved by the Court. In the interest of brevity, portions of an opinion may not have been summarized.

Gourmet Dining, LLC v. Union Township (A-8-19) (083146)

Argued March 17, 2020 -- Decided June 30, 2020

LaVECCHIA, J., writing for the Court.

The issue in this appeal is whether a high-end restaurant operated by a for-profit entity but housed in a building on the Kean University campus qualifies for exemption from local property taxation.

Under the State Constitution, all real property within New Jersey is subject to taxation unless it qualifies for a statutory exemption. N.J.S.A. 54:4-3.3 exempts from taxation property belonging to the State, counties, or municipalities, or their agencies and authorities, that is used for a public purpose. N.J.S.A. 54:4-3.6, in turn, exempts certain property of various non-profit organizations, including: “all buildings actually used for colleges, schools, academies or seminaries, provided that if any portion of such buildings are leased to profit-making organizations or otherwise used for purposes which are not themselves exempt from taxation, said portion shall be subject to taxation.”

The Legislature has also created limitations on the otherwise exempt status of property. N.J.S.A. 54:4-2.3 provides that real property entitled to tax exemption loses its exemption when leased to a person or entity whose property is not exempt. And, under N.J.S.A. 54:4-1.10, an arrangement that is not technically a lease but operates as one is subject to taxation, just as a leasehold estate would be under N.J.S.A. 54:4-2.3.

Gourmet Dining, LLC, owned and operated a fine dining restaurant named Ursino in a Kean University building. In October 2011, the Kean University Foundation, Inc., and Gourmet Dining entered into a Management Subcontract Agreement (MSA), which conferred on Gourmet Dining the exclusive right to operate, manage, and control Ursino. Gourmet Dining agreed to pay the Foundation an annual “management fee” and a percentage of Ursino’s gross revenue.

The restaurant began operation in late October 2011. In August 2012, Union Township issued a letter notifying Gourmet Dining that it would receive a tax bill for the last two months of the 2011 tax year and the entirety of the 2012 tax year. Gourmet Dining did not challenge those initial assessments but did challenge the 2013 and 2014 tax assessments. It ultimately appealed to the Tax Court. 1 The Tax Court granted summary judgment in favor of Union Township. 30 N.J. Tax 381, 391 (Tax 2018). The court first held that N.J.S.A. 54:4-3.3 applied because the University is a State governmental entity and the building constitutes governmental property. Id. at 402. Concluding that Gourmet Dining had not established that the subject property is used for a public purpose pursuant to N.J.S.A. 54:4-3.3, or that its actual use of the property was for “colleges, schools, academies or seminaries” as required by N.J.S.A 54:4-3.6, the court held that Gourmet Dining was not entitled to tax exemption under either provision. Id. at 410-13. And reasoning that the “rights, powers, and obligations conferred” through the MSA demonstrate that that agreement -- even if not denominated a lease by the parties -- is “a lease for legal purposes,” the Tax Court found the property taxable under N.J.S.A. 54:4-2.3 and N.J.S.A. 54:4-1.10. Id. at 424-26.

The Appellate Division reversed, relying on a holistic view of the following facts: the restaurant is located on-campus; University students and their parents regularly dine there; the restaurant provides students and members of the University community “an alternative dining experience”; Gourmet Dining’s annual management fees are used for scholarships; the University’s Board determined “that having a critically acclaimed, upscale restaurant on campus enhances the public’s perception of the University as a forward-looking institution, and thereby serves as an important recruiting tool”; many of the restaurant’s employees are students; and the restaurant uses produce grown on the University grounds and provides the University with compostable waste. 459 N.J. Super. 323, 327, 334-35 (App. Div. 2019). The panel also rejected the Tax Court’s conclusion that Gourmet Dining is “the ‘functional’ equivalent” of a lessee. Id. at 337.

The Court granted the Township’s petition for certification. 239 N.J. 521 (2019).

HELD: The arrangement by which Gourmet Dining operates Ursino is taxable as a lease or lease-like interest. The public-benefit-oriented exemption provisions in issue were not intended to exempt the for-profit operator of a high-end, regionally renowned restaurant situated on a college campus, when the overriding purpose of this commercial endeavor is focused on profitmaking. Gourmet Dining, as the exclusive operator and manager of this restaurant establishment, must bear its fair share of the local real property tax burden.

1. Both the Tax Court and the Appellate Division recognized that the subject property is on State property and, as such, falls within the purview of N.J.S.A. 54:4-3.3. (p. 21)

2. The Court rejects the argument, based on the punctuation of N.J.S.A. 54:4-3.3, that demonstration of a “public purpose” is unnecessary here. The State Constitution prohibits the donation of state property for private interests, and the Court has established a two-part test for determining whether a donation to a private entity violates the Constitution because it does not serve a public purpose. A court must first determine whether the provision of land or financial aid is for a public purpose, and second, whether the means to accomplish that public purpose are consonant with it. The latter 2 examination is understood as having two parts: whether the transaction is contractual and involves some obligation on the part of the private entity that is intimately tied to fulfilling the public purpose, and whether the accomplishment of the public purpose is the paramount factor in the contract with any private advantage being merely incidental or subordinate. Because an obligation of public purpose use already exists for State property, there was no need to mention the requirement in section 3.3’s first clause. Further, the public purpose assessment would remain integral to the determination of whether tax exemption would apply under N.J.S.A. 54:4-2.3 or -1.10. (pp. 21-25)

3. The Appellate Division’s holistic approach to the public purpose inquiry was mistaken. The accomplishment of the public purpose must be the paramount factor in an arrangement with a private entity’s use of public property. For a tax exemption to apply, any private advantage must be incidental or subordinate. Here, that is not so. The Court stresses that it is not assessing the University’s exercise of its authority, but rather determining whether the legislative purpose in crafting the exemption from taxation in N.J.S.A. 54:4-3.3 anticipated the circumstances here -- the University contracting out the establishment and operation of an upscale for-profit commercial restaurant to compete with other local commercial restaurants that pay their fair share of local property taxes. The Court agrees with the Tax Court that Gourmet Dining’s interest in the property is not tax exempt under that provision. (pp. 25-29)

4. The Court rejects Gourmet Dining’s claim that it is merely a manager and operator of the restaurant facility, not a tenant or lessee. Because N.J.S.A. 54:4-1.10 so clearly intends to cover user arrangements such as these, the Court relies on the Tax Court’s analysis of that statute’s applicability here. Ursino is taxable under N.J.S.A.

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