Moore v. Jackson County Assessor

CourtOregon Tax Court
DecidedJuly 24, 2024
DocketTC-MD 210339N
StatusUnpublished

This text of Moore v. Jackson County Assessor (Moore v. Jackson County Assessor) is published on Counsel Stack Legal Research, covering Oregon Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Moore v. Jackson County Assessor, (Or. Super. Ct. 2024).

Opinion

IN THE OREGON TAX COURT MAGISTRATE DIVISION Property Tax

JOHN MOORE, TRUSTEE OF THE JOHN ) & BARBARA MOORE FAMILY ) REVOCABLE TRUST, ) ) Plaintiff, ) TC-MD 210339N ) v. ) ) JACKSON COUNTY ASSESSOR, ) ) Defendant, ) ) DEPARTMENT OF REVENUE, ) State of Oregon, ) ) Defendant-Intervenor. ) DECISION

Plaintiff appeals the value of property identified as Account 10890676 (subject property)

for the 2020-21 tax year. Plaintiff requests a 2020-21 real market value (RMV) of $495,000

based on his purchase price, which Defendant Jackson County Assessor (the county) has now

agreed to. (See Or Gtg Ptf’s Mot to Am Compl, Set Br Sched, Jul 25, 2022.) The effect of that

RMV reduction is to reduce the subject property’s 2020-21 assessed value (AV) to $495,000.

(Id.) Plaintiff further requests that the subject property’s 2020-21 maximum assessed value

(MAV) and AV be reduced to $428,175. (See Ptf’s First Am Compl at 7.) Plaintiff makes

various state and federal constitutional arguments and policy arguments in support of his

requested relief. (See generally Ptf’s First Am Compl.) Plaintiff also seeks declaratory relief.

(See id. at 18.)

After filing his original Complaint, Plaintiff moved for summary judgment and the court

denied Plaintiff’s motion by Order entered June 7, 2022. That Order is incorporated herein by

reference. With leave of the court, Plaintiff filed an Amended Complaint. Defendant-Intervenor

DECISION TC-MD 210339N 1 (the department) filed a Motion to Dismiss (Motion) in response to Plaintiff’s Amended

Complaint and related briefing. This matter is now ready for the court’s determination on the

department’s Motion to Dismiss Plaintiff’s Amended Complaint.

To more fully explain the unusual posture of this case, the court begins by describing

Plaintiff’s first Motion for Summary Judgment and the court’s Order denying it. The court then

reviews Plaintiff’s Amended Complaint, the department’s Motion, and related briefing. Finally,

the court considers Plaintiff’s motion to file a second amended complaint.

I. PROCEDURAL HISTORY, RELEVANT FACTS

The court made findings of fact in the Order entered June 7, 2022, and those findings are

incorporated herein. To briefly restate key facts: the subject property was built in 1998 with

exception value added in the 1999-00 and 2000-01 tax years based on the changed property ratio

(CPR) for each year. Plaintiff purchased it for $495,000 in February 2020. Historically, the

subject property’s AV has been based on its RMV for 10 years, including the 2020-21 tax year at

issue, and based on its MAV for 14 years. Properties within the same neighborhood as the

subject property have higher RMVs yet lower property tax burdens than the subject property.

Plaintiff first moved for summary judgment arguing that the subject property’s MAV

violated Article I, section 20, of the Oregon Constitution and section 1 of the Fourteenth

Amendment to the United States Constitution (equal protection clause). (Or Deny Ptf’s Mot

Summ J at 5.) Plaintiff requested that the subject property’s MAV be reduced to achieve equal

treatment with other similar properties and that his RMV be reduced to $495,000 based on its

sale price. (Id. at 5, 7.) Plaintiff’s briefing in support of his Motion for Summary Judgment

made clear that he was not then arguing that Measure 50 was unconstitutional, but rather that the

subject property had been “denied the benefits of Measure 50 because of the arbitrary conduct of

DECISION TC-MD 210339N 2 [the county].” (Ptf’s Mot Summ J at 7.) The court denied Plaintiff’s MAV claim because his

request to adjust the subject property’s MAV relative to his neighbors was squarely addressed

and rejected by Theda v. Department of Revenue, 20 OTR 237 (2010).1 (Or Deny Ptf’s Mot

Summ J at 6-7.) The court denied Plaintiff’s RMV claim because RMV is a question of fact

inappropriate for summary judgment. (Id. at 10.)

Plaintiff next moved to file a file an amended complaint (Plaintiff’s First Amended

Complaint). The court granted Plaintiff’s motion, permitting him to add a claim challenging the

subject property’s 2020-21 MAV as violating Article I, section 20, of the Oregon Constitution.

(Or Gtg Ptf’s Mot to Am Compl, Set Br Sched, July 25, 2022.) Plaintiff’s First Amended

Complaint appears to make three essential claims:2 (1) a demand for a reduction of the subject

property’s RMV to his purchase price of $495,000; (2) a reduction of the MAV and AV to

$428,175; and (3) declaratory relief to the effect that “[t]he statutes authorizing the creation of

unequal MAVs and AVs are arbitrary and unnecessary and are unconstitutional[, that] [ORS]

308.153 and ORS 308[.]146 must be declared void[, and] [t]he repeal of Article IX, section 1[,]

and Article I, section 32[,] must be declared void.” (Ptf’s First Am Compl at 16-21.) In its

Answer to Amended Complaint, the county agreed to an RMV of $495,000 but disagreed with

Plaintiff’s other claims and reasoning. (Ans to First Am Compl at 1.) The court set a briefing

schedule on Plaintiff’s second motion for summary judgment.

1 Theda applied the holding of Nordlinger v. Hahn, 505 US 1, 112 S Ct 2326, 120 L Ed 2d 1 (1992) to Measure 50, concluding that Measure 50 did not violate the equal protection clause. (Or Deny Ptf’s Mot Summ J at 6.) 2 Plaintiff’s First Amended Complaint is 43 pages. Some pages appear to be the motion, but also make claims (Ptf’s First Am Compl at 1-4); some pages appear to be from his original Complaint, with items identified for deletion (id. at 8-15); six pages of narrative are labeled “amendments of complaint” (id. at 16-21); and the balance of the pages are Exhibits 6-9, of which only Exhibit 6 (Measure 50 ballot text) is new in this case. The court attempts to articulate and respond to Plaintiff’s claims and arguments, but the ultimate burden lies with Plaintiff to present evidence in support of his requested relief. See ORS 305.427.

DECISION TC-MD 210339N 3 In the course of briefing Plaintiff’s second motion for summary judgment, Plaintiff filed a

document titled “Service of Proceeding on Oregon Attorney General ORS 28.110,” indicating

Plaintiff had served the Attorney General with the pleadings in the case. In response, the

department filed an Answer in Intervention stating two affirmative defenses.3 The court held a

case management conference during which the court granted the department’s request to suspend

the briefing schedule on Plaintiff’s second motion for summary judgment to allow the

department to file a motion to dismiss. The court set a new briefing schedule on the

department’s motion to dismiss. In lieu of the response brief permitted by the court, Plaintiff

responded to the department’s motion to dismiss with a motion to file a second amended

complaint (Plaintiff’s Second Motion to Amend). In its reply, the department opposed Plaintiff’s

Second Motion to Amend and requested the court deny the same due to prejudice upon

defendants and due to the futility of the proposed amendments. (See generally Inv’s Resp to

Ptf’s Mot to File Sec Am Compl.) Plaintiff subsequently filed three successive documents of

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Moore v. Jackson County Assessor, Counsel Stack Legal Research, https://law.counselstack.com/opinion/moore-v-jackson-county-assessor-ortc-2024.