Petrin v. Town of Scarborough

CourtSuperior Court of Maine
DecidedJanuary 11, 2019
DocketCUMap-18-26
StatusUnpublished

This text of Petrin v. Town of Scarborough (Petrin 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
Petrin v. Town of Scarborough, (Me. Super. Ct. 2019).

Opinion

STATE OF MAINE SUPERIOR COURT

Cumberland, ss. REC'D CUMS CLERKS Ofl DONALD PETRIN et als., JAN 14 '19 AM8:3?

Plaintiffs V. Docket No. PORSC-AP-18-26 /

TOWN OF SCARBOROUGH,

Defendant

KENYON BOLTON, III et als.,

Plaintiffs V. Docket No. PORSC-AP-18-30 t,/

ANGELL FAMILY 2012 PROUTS NECK TRUST et als.,

Plaintiffs v. Docket No. PORSC-AP-18-24 /

TOWN OF SCARBOROUGH

Plaintiff V. Docket No. PORSC-AP-18-31 ../

DONALD PETRIN et als.,

Defendants

1 DECISION AND JUDGMENT

The Plaintiff taxpayers ["the Taxpayers"] in three of these consolidated cases

have appealed pursuant to M.R. Civ. P. 80B and .'36 M.R.S. § 843 from the decision of

the Town of Scarborough Board of Assessment Review ["Board"] on the Taxpayers'

applications for property tax abatements. The fourth case is a Rule BOB appeal from

the same decision taken by the taxing municipality, the Town of Scarborough

[ "T own"] .

The cases were consolidated for purposes of briefing and scheduling.

The two issues presented in the Taxpayers' appeals are:

(a) what remedy in terms of tax abatements should be granted to Taxpayers?

A sub-issue is whether the Taxpayers are constitutionally entitled to the abatement

they seek or simply entitled to a reasonable abatement.

(b) what rate or rates of interest should the Town be required to pay on the tax

abatements and over what period should interest run?

The Board decision at issue is the second decision the Board has made regarding

the Taxpayers' abatement requests. The court vacated the first decision, and the

Town's appeal asks the court, in effect, to change that ruling and reinstate the first

decision.

Background

The Taxpayers all own property in the Town of Scarborough. The Taxpayer

Plaintiffs in the Petrin case own property in the Pine Point and Higgins Beach areas

2 of Scarborough. The Taxpayer Plaintiffs in the Bolton and Angell Family cases all own

properties on or near Prouts Neck in Scarborough, where average land values are far

higher than average land values in the Pine Point and Higgins Beach areas.

In Scarborough, property taxes due for a given tax year are paid in two equal

installments.

This is the third round of appeals that the three sets of Taxpayers have taken

from the Board's decisions on their abatement requests. In each instance, the appeals

of the three sets of Taxpayers were consolidated for all purposes.

The Taxpayers' first round ofappeals were heard in the Business and Consumer

Court initially and then in the Supreme Judicial Court of Maine, sitting as the Law

Court. See Petrin v. Town ef Scarborough, 2015 Me. Super. LEXIS 37 (Docket No.

BCD-AP-14-03), vacated and remanded in part, 2016 ME 136, 147 A.3d 842; Angell

Family 2012 Prouts Neck Trust v. Town ef Scarborough, Me. Bus. & Consumer Ct.,

Docket No. CV-14-59, vacated and remanded in par~ 2016 ME 152, 149 A.sd 271.

Those appeals challenged the Town's revaluation of waterfront and water-influenced

properties, and also challenged the constitutionality of the Town's program for

assessing separate but abutting parcels held in common ownership ["the abutting

property program"].

The Law Court rejected the Taxpayers' appeals on most of the grounds they

advanced, but upheld the appeals as they related to the abutting property program:

The abutting property program allows a taxpayer who owns multiple abutting properties to elect to have the separate lots assessed as a single unit. The abutting property program results in a lower valuation of the

s two lots than if they were assessed independently of each other." Angell Family 2012 Prouts Neck Trust v. Town ofScarborough, 2016 ME 152, ~ 16, 149 A.sd 271 (internal ellipses omitted). "This necessarily means that those who do not own abutting properties are subjected to taxes that are not imposed on owners oflots that happen to be abutting."

Petrin v. Town of Scarborough, 2016 ME 1.36, ~Sl, 147 A.sd 842.

The Law Court concluded that the Town's abutting property program

"necessarily results in an unequal apportionment of the tax burden," Angell, 2016 ME

152 at ~21, and violates the Taxpayers' right to equal protection. Petrin, 2016 ME

1.36 at ~~S 1-.32. Accordingly, the Law Court remanded the Taxpayers' appeals to the

Business and Consumer Court, with directions that the appeals be remanded to the

Board for "further proceedings to address the inequality in tax treatment affecting the

Taxpayers because of the abutting property program." Petrin v. Town ofScarborough,

2016 ME 1.36 at ~s2, 147 A.sd 842.

In remanding the case, the Law Court did not address what remedy the Board

should grant the Taxpayers, but the parties agree that the appropriate remedy is for

the Board to grant the Taxpayers a property tax abatement for each of the four tax

years at issue-tax years 2012, !WIS, 2014 and 2015. They also appear to agree that

the abatement should pertain only to the Taxpayers' land assessment, because the

discriminatory abutting property program benefited only the owners of unimproved

abutting properties.

On the other hand, the parties have a fundamental disagreement about how the

amount of the abatement should be determined. The Taxpayers have argued

consistently that they are constitutionally entitled to the same S 1.48% reduction in

4 the valuation of the land portion of their properties that the beneficiaries of the

discriminatory program received, on average, over the four tax years at issue. See

Plaintiffs' Joint Rule BOB Reply Brief at 3 ("For reasons they have already explained,

Taxpayers believe a 31.48% reduction.in land assessments represents a fair "rough

equality" with those in the abutting property program. Some in the program got

higher benefits, but some also got lower - the 31.48% is the average reduction and

therefore a type of midpoint of the benefits of the illegal abutting property program.")

The Town, however, asserts that the Taxpayers are only entitled to a

reasonable abatement, based on the statute that calls for taxpayers whose property is

over-assessed to receive a "reasonable" abatement. See 36 M.R.S. § 843( 1). 1

The Business and Consumer Court remanded the appeals to the Board without

retaining jurisdiction.

On remand, the Board decided to grant an abatement to the Taxpayers

measured by the total dollar value of the benefit that the abutting property program

had conferred upon the lot owners who participated in the program in a given tax

year, divided by the number of Taxpayers who filed appeals in each year. Thus, for

example, the $116,836.32 that the abutting property program had saved the

participating property owners for the 2012-13 tax year would be distributed among

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