Loiseau v. Board of Tax Review

699 A.2d 265, 46 Conn. App. 338, 1997 Conn. App. LEXIS 432
CourtConnecticut Appellate Court
DecidedAugust 19, 1997
DocketAC 16627
StatusPublished
Cited by10 cases

This text of 699 A.2d 265 (Loiseau v. Board of Tax Review) is published on Counsel Stack Legal Research, covering Connecticut Appellate Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Loiseau v. Board of Tax Review, 699 A.2d 265, 46 Conn. App. 338, 1997 Conn. App. LEXIS 432 (Colo. Ct. App. 1997).

Opinion

Opinion

DUPONT, C. J.

The plaintiffs, Edward M. Loiseau and Lucille G. Loiseau, appeal from the trial court’s denial of their motion to open the judgment after the trial [339]*339court granted a judgment of dismissal for failure to make out a prima facie case in favor of the defendant board of tax review. We reverse the judgment of the trial court.

On April 15, 1994, the plaintiffs appealed to the trial court from the February 25, 1994 decision of the board of tax review of the town of Suffield (board), claiming that the board’s valuation of their property as of October 1, 1993,1 was grossly excessive, disproportionate, unlawful and not in accordance with the uniform percentage of true and actual valuation as required by statute.2 The plaintiffs asked that the valuation be [340]*340reduced equitably and proportionately in accordance with the uniform percentage of true and actual valuation as required by statute to be used by the assessor and the board. The application was later amended to include the tax years of 1994 and 1995.

A trial to the court was held on December 12, 1995, and February 29, 1996. At trial, the plaintiffs called David Collins, a real estate appraiser, as their expert witness. In the fall of 1993, Collins had taken over the appraisal of the subject property from Edward Lynch, whom the plaintiffs had originally hired to appraise their property. Lynch died prior to trial. The appraisal reports that Collins presented at trial were in Lynch’s name and bore Lynch’s signature, although Collins testified that he had created them based on Lynch’s preliminary work.

Three reports produced by Lynch and Collins were introduced into evidence. The plaintiffs introduced the first, which had a date of value of October 1, 1989, the date of the last town-wide revaluation of the town of Suffield. The defendant introduced two other versions of the same document, with dates of value of October 1, 1992, and October 1, 1993. The appraisal dated 1993 had been part of an exchange of evidence between the two parties at a pretrial conference and was apparently a draft version. The appraisal dated 1992 had been given by the plaintiffs to the defendant a few weeks before trial in exchange for the defendant’s final appraisal. Subsequent to the exchange, the plaintiffs discovered several typographical errors in the document, including [341]*341the date of value, and gave the corrected version, with the 1989 date, to the defendant shortly before trial. The three versions each contain different conclusions regarding the value of the property, ranging from $190,500 to $200,000.

A review of the transcripts demonstrates that Collins’ testimony was often unclear and sometimes contradictory regarding his method of appraisal of the property. He testified that, in his expert opinion, the property had a fair market value of $200,000 in 1989. He used the income approach in appraising the property, which is a valuation method that determines property value by derivation of the rental value of the property and may include anticipated future income that has been discounted to a present value. His testimony as to fair market value and his method of appraisal, however, was not unequivocal.

Following Collins’ testimony, the plaintiffs called as a witness Paul Champagne, the appraiser and expert witness for the defendant. The defendant objected on the grounds that Champagne was not the plaintiffs’ witness and was not disclosed by the plaintiffs as an expert to be called by them, and that Champagne’s report was the work product of the defendant. The defendant argued that the plaintiffs could examine its expert on cross-examination but could not examine him on direct during the course of the plaintiffs’ case. Champagne was allowed to take the stand, but was not allowed to reveal the figure at which he had valued the property. The court also did not allow the plaintiffs to introduce Champagne’s report into evidence, reasoning that the report, which contained the figure at which he valued the plaintiffs’ real estate, would be the same as allowing Champagne to testify as to value.

After the plaintiffs rested, the defendant, without having conducted a direct examination of Champagne, [342]*342moved for a judgment of dismissal, claiming that the plaintiffs had not made out a prima facie case.3 The trial court granted the motion for judgment of dismissal. The plaintiffs’ subsequent motion to open the judgment was denied. This appeal followed.

When a plaintiff has failed to prove its prima facie case, it is proper for a court to grant the defendant’s motion for judgment of dismissal pursuant to Practice Book § 302. See Rosenfield v. Cymbala, 43 Conn. App. 83, 91, 681 A.2d 999 (1996). A court may find that a plaintiff has failed to make out a prima facie case “when the evidence produced by the plaintiff, if fully believed, would not permit the trier in reason to find the essential issues on the complaint in favor of the plaintiff.” Minicozzi v. Atlantic Refining Co., 143 Conn. 226, 230, 120 A.2d 924 (1956); see also Hinchliffe v. American Motors Corp., 184 Conn. 607, 609, 440 A.2d 810 (1981), on appeal after remand, 192 Conn. 252, 470 A.2d 1216 (1984). “In considering a motion under Practice Book § 302, a trial court must consider all of the plaintiffs evidence to be true. . . . Further, a trial court must draw all inferences in the plaintiffs favor.” (Citations omitted; internal quotation marks omitted.) Walshon v. Walshon, 42 Conn. App. 651, 654, 681 A.2d 376 (1996).

“On appeal of a dismissal pursuant to Practice Book § 302, we take the plaintiffs evidence as true; Higgins v. Ambrogio, 19 Conn. App. 581, 584, 562 A.2d 1154 (1989); and consider the trial court’s conclusions in light of the evidence in the record. Bershtein, Bershtein & [343]*343Bershtein v. Nemeth, 221 Conn. 236, 239, 603 A. 2d 389 (1992) . ‘Whether the plaintiffs established a prima facie case is a question of law.’ Wordie v. Staggers, 27 Conn. App. 463, 465, 606 A.2d 734 (1992); Angelo Tomasso, Inc. v. Armor Construction & Paving, Inc., 187 Conn. 544, 561, 447 A.2d 406 (1982). ‘We must determine whether the trial court properly determined that the plaintiff failed to provide sufficient evidence to support his prima facie case.’ Ivimey v. Watertown, 30 Conn. App. 742, 751, 622 A.2d 603, cert. denied, 226 Conn. 902, 625 A.2d 1375 (1993), citing Logan v. O’Neill, 187 Conn. 721, 728, 448 A.2d 1306 (1982).” Discover Leasing, Inc.

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Bluebook (online)
699 A.2d 265, 46 Conn. App. 338, 1997 Conn. App. LEXIS 432, Counsel Stack Legal Research, https://law.counselstack.com/opinion/loiseau-v-board-of-tax-review-connappct-1997.