Lebovitz v. Town of Scarborough

CourtSuperior Court of Maine
DecidedJune 6, 2003
DocketCUMap-02-46
StatusUnpublished

This text of Lebovitz v. Town of Scarborough (Lebovitz 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
Lebovitz v. Town of Scarborough, (Me. Super. Ct. 2003).

Opinion

012 SUPERIOR COURT

STATE OF MAINE CUMBERLAND, ss. gree CIVIL ACTION “= DOCKET NO. AP-02-4 n: _ . BEC~ CHU b/o hv oud Oo RM ie fy ROBERT LEBOVITZ and CAROLYN LEBOVITZ Plaintiffs, DONALD L. GARBRECHT LAW LIBRARY Vv. ORDER ON 80B APEAL.: JUN 16 2005 TOWN OF SCARBOROUGH, Defendant.

Plaintiffs Robert and Carolyn Lebovitz appeal from the July 22, 2002 decision of the Town of Scarborough Board of Assessment Review (Board), in which the Board upheld the Town Tax Assessor’s (Assessor’s) valuation of the Plaintiffs’ property.

FACTUAL BACKGROUND

Plaintiffs own unit #12 of the Atlantic House Condominiums in Scarborough. The Atlantic Place Condominiums are located on coastal property adjacent to Scarborough Beach. Plaintiffs purchased unit #12 in 1991 for $750,000.'_ For the 2001 tax year, the Assessor assessed Plaintiffs’ property at $707,000. Plaintiff asserts that the fair market value of the property is $486,700. By unanimous vote, the Board denied Plaintiffs’ appeal of the Assessor’s valuation.

Atlantic House is comprised of 42 units of five different floor plans (A-E). Plaintiffs’ unit is an A unit. A units are most similar to D units. Most A units have a full

basement. Plaintiffs’ unit does not; it has only a crawlspace, for which it received a

negative adjustment.

' The Real Estate Transfer Tax form reported to the Town indicates a price of $750,000. Plaintiffs provided documentation demonstrating that the seller assumed a “buy-down” credit, resulting in an. effective purchase price of $611,281. The Plaintiffs’ brief does not clearly identify the legal arguments presented on appeal. In light of the standard of review, the Plaintiffs’ elusive arguments may be reduced to three legal contentions: the Assessor’s valuation of the Plaintiffs’ property is manifestly wrong, because either 1) the judgment of the assessor was irrational, or was so unreasonable in light of the circumstances that the property was substantially overvalued and an injustice resulted; 2) the Plaintiff was unjustly discriminated against in the valuation of his property; or 3) the assessment was illegal because it did not consider all of the factors identified in 36 M.R.S.A. § 701-A (2002).

The Board argues that all of the “evidence” presented at the hearing was properly weighed or, if appropriate, excluded by the Assessor and the reasoning and support for those decisions were presented to the Board. Defendant, therefore contends that there was sufficient support on the record for the Board’s decision; that Plaintiffs failed to meet their burden to prove the assessment was manifestly wrong; that the Board acted properly in not completing an independent valuation of the ptoperty; and that Plaintiffs’ contention that the Assessor illegally relied upon sales data from after the statutory date of valuation is not supported by the evidence and is not sufficient by itself to permit the court to overturn the assessment.

DISCUSSION

A decision of the Board of Assessment Review is reviewed for errors of law, abuse of discretion, or findings of fact not supported by substantial evidence in the

record. Griffin v. Town of Dedham, 2002 ME 105, 7 6, 799 A.2d 1239. The Board’s

analysis begins with the presumption that the assessor's valuation of the property is

valid. Chase v. Town of Machiasport, 1998 ME 260, ] 13, 721 A.2d 636. See also

Muirgen Properties, Inc. v. Town of Boothbav, 663 A.2d 55, 58 (Me.1995) (discussing

burden and standard of review); Sweet v. City of Auburn, 134 Me. 28, 33, 180 A. 803 (1935) (citing Penobscot Chemical Fibre Co. v. Town of Bradley, 99 Me. 263, 267-69, 59

A. 83 (1904)). The Plaintiff taxpayer bears the burden of establishing before the Board of Assessment Review that “the assessed valuation in relation to the just value is

manifestly wrong.” Weekley v. Town of Scarborough, 676 A.2d 932, 934 (Me. 1996).

“[A] taxpayer may not meet his or her burden of proving that the assessor was manifestly wrong by merely impeaching the Town's assessment. Rather, the taxpayer must come forward with credible, affirmative evidence of just value.” Town of

Southwest Harbor v. Harwood, 2000 ME 213, { 9, 763 A.2d 115 (quotation omitted); see

also” Yusem v. Town of Raymond, 2001 ME 61, { 13, 769 A.2d 865( “Impeachment of

the assessor's methodology alone is insufficient to meet that burden. The taxpayer must demonstrate that the property is overrated.”). Only if the Board determines that Plaintiffs have offered sufficient credible evidence of overvaluation, must the Board

then undertake an independent valuation of the property.” Northeast Empire Ltd.

P’ship #2 v. Town of Ashland; 2003 ME 28, | 8, 818 A.2d 1021. “Because the Board

concluded that the [Plaintiffs] failed to meet their burden of proof, we will vacate that decision only if the evidence compels a contrary conclusion to the exclusion of any

other inference.” Yusem v. Town of Raymond, 2001 ME 61, { 9, 769 A.2d 865;

McCullough v. Town of Sanford, 687 A.2d 629, 631(Me. 1996).

“To meet the initial burden of showing that the assessment was manifestly wrong, the taxpayer must demonstrate that (1) the judgment of the assessor was

irrational or so unreasonable in light of the circumstances that the property was

* “Tf but only if, the taxpayer meets that burden, the [Board] must engage in ‘an independent determination of fair market value .. . based on a consideration of all relevant evidence of just value.’” Id., § 8 (quoting Quoddy Realty Corp. v. City of Eastport, 1998 ME 14, 45,704 A.2d 407).

substantially overvalued and an injustice resulted; (2) there was unjust discrimination;

or (3) the assessment was fraudulent, dishonest, or illegal.” Yusem v. Town of

Raymond, 2001 ME 61, { 9, 769 A.2d 865.

1) Overvaluation Due to Irrational and/or Unreasonable Judgment by the Assessor

Plaintiffs claim that the assessment of their property is unreasonable in light of the surrounding circumstances: failure to use the income approach to valuation, failure to consider sales from the mid-1990s that supported a lower valuation, and failure to account for conditions such as lack of view, Wear, and disrepair.

Based on the evidence, Plaintiffs have “not demonstrated that the evidence

compels a contrary conclusion to the exclusion of any other inference.” McCullough v.

Town of Sanford, 687 A.2d at 631. To the contrary, at the hearing before the Board, the

Assessor thoroughly addressed each of Plaintiffs’ arguments regarding numerous facets of the valuation process (i.e. method, lack of view, proximity to waterfront, and incomparability to neighboring single-family residences). R. Tab 1, Tr. at 6-9, 15, 20-21.

ae fo - : «

2) ‘Unjust Discrimination

Plaintiffs’ only clear reference to an unjust discrimination claim is found in the last paragraph of the Reply Brief;* “[t]he Assessor did not value Plaintiffs’ property uniformly with similar properties ....” Pls.’ Reply at 11. Unjust discrimination was also mentioned in the minutes at the hearing before the Board. R. Tab 1, Tr. at 14 (Board Chairperson: “[Y]our task is to prove that you have been unfairly and unjustly assessed in relationship to your [sic] other properties.”: Lebovitz: “I think my assessment was unfair.”). “Only if taxpayers can show that the assessors’ system necessarily will result

in unequal apportionment do they not have to show that their property is substantially

overvalued. Wesson v.

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Related

Griffin v. Town of Dedham
2002 ME 105 (Supreme Judicial Court of Maine, 2002)
Muirgen Properties, Inc. v. Town of Boothbay
663 A.2d 55 (Supreme Judicial Court of Maine, 1995)
Chase v. Town of MacHiasport
1998 ME 260 (Supreme Judicial Court of Maine, 1998)
Kittery Electric Light Co. v. Assessors of Kittery
219 A.2d 728 (Supreme Judicial Court of Maine, 1966)
Quoddy Realty Corp. v. City of Eastport
1998 ME 14 (Supreme Judicial Court of Maine, 1998)
South Portland Associates v. City of South Portland
550 A.2d 363 (Supreme Judicial Court of Maine, 1988)
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)
McCullough v. Town of Sanford
687 A.2d 629 (Supreme Judicial Court of Maine, 1996)
Yusem v. Town of Raymond
2001 ME 61 (Supreme Judicial Court of Maine, 2001)
Penobscot Chemical Fibre Co. v. Inhabitants of Bradley
59 A. 83 (Supreme Judicial Court of Maine, 1904)
Alfred J. Sweet, Inc. v. City of Auburn
180 A. 803 (Supreme Judicial Court of Maine, 1935)
Northeast Empire Ltd. Partnership 2 v. Town of Ashland
2003 ME 28 (Supreme Judicial Court of Maine, 2003)

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Lebovitz v. Town of Scarborough, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lebovitz-v-town-of-scarborough-mesuperct-2003.