MCCC DISTRICT v. MARICOPA COUNTY

Court of Appeals of Arizona·Decided July 29, 2026·No. 1 CA-TX 25-0002·Unpublished·David B. Gass

Opinion

NOTICE: NOT FOR OFFICIAL PUBLICATION.

UNDER ARIZONA RULE OF THE SUPREME COURT 111(c), THIS DECISION IS NOT PRECEDENTIAL AND MAY BE CITED ONLY AS AUTHORIZED BY RULE.

IN THE ARIZONA COURT OF APPEALS DIVISION ONE

MARICOPA COUNTY COMMUNITY COLLEGE DISTRICT, Plaintiff/Appellant,

v.

MARICOPA COUNTY, et al., Defendants/Appellees.

No. 1 CA-TX 25-0002 FILED 07-29-2026

Appeal from the Arizona Tax Court No. TX2025-000046

Maricopa County Superior Court No. CV2025-001139 The Honorable Erik Thorson, Judge

AFFIRMED

COUNSEL

Ballard Spahr LLP, Phoenix By John Kerkorian, Mitchell Turbenson, and Augustine Cinquino Counsel for Plaintiff/Appellant

Fennemore Craig, PC, Phoenix By Patrick Irvine, Spencer A. Shockness, and Claire A. MacCollum Counsel for Defendants/Appellees

Decision of the Court

MEMORANDUM DECISION

Presiding Judge David B. Gass1 delivered the decision of the court, in which Judge Anni Hill Foster and Judge D. Andrew Gaona joined.

G A S S, Judge:

¶1 Over several years, Maricopa County assessed excess property taxes, causing taxpayers to overpay their taxes. During that time, the County distributed a portion of those overpayments to the Maricopa County Community College District. In a separate action, taxpayers sued the County over the assessed taxes and eventually won, resulting in a judgment against the County. The County refunded the taxpayers for the overpayments plus interest under that judgment and then recouped a proportional amount of the overpayments from the District. The District filed a special action against the County and the County Treasurer to challenge the amount and timing of the recoupment. The superior court denied the County relief.

¶2 The District appeals that order, arguing the County could not recover interest in the 2024 judgment. The District also argues the County recouped the money too soon under A.R.S. § 42.16214.A. Because interest applies to the judgment under A.R.S. § 42-16214.C, and A.R.S. § 42-16214.A requires the County to subtract the amount of the judgment “from the amounts due to taxing jurisdictions in the next fiscal year,” the court affirms.

FACTUAL AND PROCEDURAL HISTORY

¶3 The District and Maricopa County are separate political subdivisions of the State of Arizona and constitute distinct taxing districts.

1 Judge David B. Gass was a sitting member of this court when the matter was assigned to this panel of the court. He retired effective June 30, 2026. In accordance with the authority granted by Article VI, Section 3, of the Arizona Constitution, and under A.R.S. § 12-145, the Chief Justice of the Arizona Supreme Court has designated Judge David B. Gass as a judge pro tempore in the Court of Appeals for the purpose of participating in the resolution of cases assigned to this panel during his term in office and for the duration of Administrative Order 2026-87.

Decision of the Court

See A.R.S. Const. Art. 9 § 19; A.R.S. § 35-511(2). The County Treasurer is a party in his official capacity.

¶4 After the District determines the budget for the current fiscal year, the County Assessor values properties based on their assessment valuations and then applies the applicable tax rate. See A.R.S. § 42-13051; A.R.S. §§ 42-15001 to -15010; Machu Picchu Holdings, LLC v. Pinal Cnty., 255 Ariz. 73, 76 ¶ 3 (App. 2023). The Treasurer then pays the District its allocated share. A.R.S. § 42-6205.B.3.

I. This action arises from a stipulated judgment between the County and a class of the plaintiffs in Qasimyar v. Maricopa County (the Qasimyar action).

¶5 Between 2016 and 2021, several groups of plaintiffs filed class action complaints against the County in which they challenged the County Assessor’s classification for property tax purposes.

¶6 The plaintiffs first challenged the Assessor’s classification decisions at the State Board of Equalization. Though the Board agreed the County Assessor improperly classified the properties, it did not find the County overcharged the taxpayers under A.R.S. § 42-13302. The plaintiffs appealed that decision to the superior court, which consolidated all the class action cases into the Qasimyar action.

¶7 A year and a half later (in June 2018), the superior court granted plaintiffs’ motion for partial summary judgment. The County appealed, and the court affirmed. See Qasimyar v. Maricopa Cnty., 250 Ariz. 580, 590 ¶ 34 (App. 2021).

¶8 Several years later (February 2024), the superior court eventually entered a stipulated judgment (the Qasimyar judgment). The reason for the multi-year delay is unclear. The judgment included damages in the amount the plaintiffs overpaid in property taxes from 2015 through 2021, depending on the year the plaintiffs filed their action, and accrued interest.

[A]s a result of reductions of limited property values provided herein, Defendant Maricopa County shall calculate any excess property taxes levied, assessed, and timely paid and shall pay to the respective owner[s] of each parcel in the classes a property tax refund, less any applicable attorneys’ fees awarded below, in an amount equal to the excess property taxes paid, plus interest at the legal rate payable

Decision of the Court

from the date of overpayment until the judgment is paid in full as provided in A.R.S. §§ 42-16214 and 42-1123.

¶9 The judgment also addressed taxes paid in the years after the plaintiffs filed their actions.

[A]s it relates to plaintiffs’ claims for refunds in subsequent years based on the changes for each parcel[’s] initial year in litigation . . . those claims for additional years . . . are hereby dismissed, conditioned on the fact that, by operation of law, Defendant Maricopa County will correct its tax rolls as to all parcels included in the classes in all subsequent tax years and issue, where required by law, refunds with statutory interest.

¶10 The superior court signed the judgment on February 2, 2024, during the fiscal year 2023-24. Fiscal year 2024-25 ran from July 1, 2024, through June 30, 2025.

II. Several months later, the District learned about the County’s plan to recoup the judgment from the District and the other taxing districts.

¶11 The District learned about the recoupment in June 2024. For the District, the recoupment request came as a surprise. The District was neither involved in the Qasimyar action in any capacity nor consulted by the County. The County admits it did not notify the District about the Qasimyar action and did not explain its plan to withhold funds from the District to fulfill the judgment. But the County claims it had no duty to communicate with the District, and the District does not challenge that claim.

¶12 Whatever the County’s notification obligations, the Treasurer estimated the District owed the County $44,686,487. The District wrote to the Treasurer, the Maricopa County Board of Supervisors, and the Maricopa County Manager requesting a complete accounting of the financial effect on the District. The District contends its governing board already approved its budget for the 2024-25 fiscal year, which began on July 1, 2024, and thus had no ability to plan or budget for the unanticipated expense.

¶13 Even so, the Treasurer began recouping the overpayments and interest from monies the County held in an account for the District in August 2024, ultimately taking $45,954,754.29, with $8,523,126 of accrued interest.

Decision of the Court

¶14 The District filed a notice of claim with the County and the Treasurer. After more than 60 days passed, the District filed a special action against the County and the Treasurer.

III. The District’s complaint sought special action/mandamus relief, declaratory judgment, an accounting, and restitution.

¶15 The County answered and denied the District’s right to relief. The County then asserted the complaint failed to state a claim upon which relief can be granted and that the District’s proposed resolution would unjustly enrich the District.

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MCCC DISTRICT v. MARICOPA COUNTY, (Ark. Ct. App. 2026).

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