LOVE v. FULTON COUNTY BOARD OF TAX ASSESSORS

859 S.E.2d 33, 311 Ga. 682
CourtSupreme Court of Georgia
DecidedJune 1, 2021
DocketS21A0329
StatusPublished
Cited by23 cases

This text of 859 S.E.2d 33 (LOVE v. FULTON COUNTY BOARD OF TAX ASSESSORS) is published on Counsel Stack Legal Research, covering Supreme Court of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
LOVE v. FULTON COUNTY BOARD OF TAX ASSESSORS, 859 S.E.2d 33, 311 Ga. 682 (Ga. 2021).

Opinion

311 Ga. 682 FINAL COPY

S21A0329. LOVE et al. v. FULTON COUNTY BOARD OF TAX ASSESSORS et al.

ELLINGTON, Justice.

This case arose from a taxpayer grievance concerning whether

the Fulton County Board of Tax Assessors (the “Board”) had been

diligent in determining that the Atlanta Falcons Stadium Company

LLC (“StadCo”), had a usufruct interest in the Mercedes-Benz

Stadium that was not subject to ad valorem taxation. In 2017, Albert

E. Love and other Fulton County taxpayers (the “appellants”) sued

the Board, the individual members of the Board, and the Board’s

Chief Appraiser, seeking mandamus and other relief.1 Since then,

1 The appellants (plaintiffs below) are Love, Gregory L. Fann, Sr., Anthony Kristian Vatalaro, Catherine Rachel Flood, Peter Zyskowski, and Lynn Zyskowski. The plaintiffs originally sued Fulton County; the Board; Board members Salma Ahmed, Michael Fitzgerald, Brandi Hunter, Ed London, and Royce Morris; and the Board’s Chief Appraiser, Dwight Robinson. The plaintiffs sued the Board members and the Chief Appraiser in their official and individual capacities. In their fourth amended petition, the plaintiffs sued Fulton County; the Board; Board members Salma Ahmed, Michael Fitzgerald, Edward London, Lisa Aman, and Pamela Smith; the Board’s Chief Appraiser,

1 the suit has been dismissed, appealed to the Court of Appeals, see

Love v. Fulton County Bd. of Tax Assessors, 348 Ga. App. 309 (821

SE2d 575) (2018), remanded, amended to add claims and

intervenors, and then dismissed again.

At issue in this appeal is whether the trial court properly

dismissed the appellants’ fourth amended petition, which asserted

claims for mandamus, declaratory and injunctive relief, and a

refund of taxes paid. In support of its claims, the appellants asserted

that the Board and its members had committed a gross abuse of

discretion by failing to find that StadCo had a leasehold interest in

the stadium that is subject to ad valorem taxation. The appellants

also asserted that the Board’s decision was based on an

“unconstitutionally adopted” exemption codified in OCGA § 10-9-10.

The appellees and intervenors StadCo and the Georgia World

Dwight Robinson; and the Fulton County Tax Commissioner, Arthur E. Ferdinand. (The trial court, however, denied the plaintiffs’ motion to add Fulton County and the Fulton County Tax Commissioner as defendants.) In the fourth amended petition, the plaintiffs modified two of their claims (Count I for declaratory relief, and Count II for injunctive relief) to sue the Board members and the Chief Appraiser in their individual capacities only. 2 Congress Center Authority (“GWCCA”) answered and filed motions

arguing, among other things, that the Board had properly

determined that StadCo’s interest was a non-taxable usufruct after

conducting an investigation and holding a hearing at which they

considered evidence concerning the nature of StadCo’s interest.

They also argued that the Board’s decision was not based on OCGA

§ 10-9-10 but on an evaluation of agreements entered into between

the intervenors prior to the construction of the stadium. In its order

dismissing the case, the trial court addressed each of the appellants’

claims and found that the petition lacked any legal basis for

recovery. On appeal, the appellants contend that the trial court

erred in dismissing the petition, allegedly sua sponte, arguing

primarily that the trial court had applied an incorrect standard of

review. They also contend that the trial court erred in declining to

find OCGA § 10-9-10 unconstitutional. For the following reasons, we

see no error and affirm the judgment.

A motion to dismiss for failure to state a claim upon which relief may be granted should not be sustained unless (1) the allegations of the complaint disclose with

3 certainty that the claimant would not be entitled to relief under any state of provable facts asserted in support thereof; and (2) the movant establishes that the claimant could not possibly introduce evidence within the framework of the complaint sufficient to warrant a grant of the relief sought.

(Footnotes omitted.) Anderson v. Flake, 267 Ga. 498, 501 (2) (480

SE2d 10) (1997). See also OCGA § 9-11-12 (b) (6). In assessing

whether a claim should be dismissed, a court may consider exhibits

attached to and incorporated into the complaint and answer. See

OCGA § 9-11-10 (c) (“A copy of any written instrument which is an

exhibit to a pleading is a part thereof for all purposes.”); Minnifield

v. Wells Fargo Bank, 331 Ga. App. 512, 514-515 (2) (771 SE2d 188)

(2015) (“When considering a motion to dismiss for failure to state a

claim, a trial court may consider exhibits attached to and

incorporated into the complaint and answer.” (citation omitted)). To

the extent there are inconsistencies between the allegations in the

complaint and exhibits attached to the complaint, the exhibits

control. See Lord v. Lowe, 318 Ga. App. 222, 223-224 (741 SE2d 155)

(2012). The appellate court “review[s] de novo the trial court’s ruling

4 on the [defendants’] motion to dismiss, accepting as true all well-

pled material allegations in the complaint and resolving any doubts

in favor of [the plaintiff].” Greene County School Dist. v. Circle Y

Constr., 291 Ga. 111, 112 (728 SE2d 184) (2012).

1. According to the fourth amended petition and its exhibits,

before the new stadium was built, the GWCCA owned and operated

the Georgia Dome, which was the home venue for the Atlanta

Falcons professional football team. Prior to investing $1.5 billion to

construct the new stadium, the parties involved in the project

entered into a number of agreements concerning the tax

ramifications of their interests in the stadium. On April 5, 2013,

GWCCA, StadCo, and Atlanta Falcons Football Club, LLC (the

“Club”), entered into a “Memorandum of Understanding for a

Successor Facility to the Georgia Dome” (the “MOU”). That same

day, GWCCA, the Atlanta Development Authority d/b/a Invest

Atlanta (“Invest Atlanta”), and StadCo entered into a “Tri-Party

Memorandum of Understanding for a Successor Facility to the

Georgia Dome” (the “Tri-Party MOU”).

5 With respect to taxation, the MOU states that “[n]either

StadCo nor the GWCCA expect any ad valorem taxes to be payable

with respect to their respective interests in such real property and

improvements for the [stadium project], and neither Party will in

any event assume or undertake any ad valorem tax responsibilities

or liabilities of the other.” The MOU further provided that “StadCo

shall have received confirmation from the [Board] or other

appropriate governmental authority in form reasonably satisfactory

to StadCo that StadCo’s and the Club’s rights with respect to the

[stadium] under the License Agreement and related agreements will

constitute a usufruct.”2 On August 6, 2013, StadCo’s counsel

provided the Board and the Board’s Chief Appraiser with a lengthy

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Bluebook (online)
859 S.E.2d 33, 311 Ga. 682, Counsel Stack Legal Research, https://law.counselstack.com/opinion/love-v-fulton-county-board-of-tax-assessors-ga-2021.