Regency Intrastate Gas, LLC v. Louisiana Tax Commission and Scott Meredith, Assessor of Caldwell Parish

CourtLouisiana Court of Appeal
DecidedSeptember 27, 2021
Docket2021CA0271, 2021CA0273, 2021CA0272
StatusUnknown

This text of Regency Intrastate Gas, LLC v. Louisiana Tax Commission and Scott Meredith, Assessor of Caldwell Parish (Regency Intrastate Gas, LLC v. Louisiana Tax Commission and Scott Meredith, Assessor of Caldwell Parish) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Regency Intrastate Gas, LLC v. Louisiana Tax Commission and Scott Meredith, Assessor of Caldwell Parish, (La. Ct. App. 2021).

Opinion

STATE OF LOUISIANA COURT OF APPEAL FIRST CIRCUIT

NUMBER 2021 CA 0271

REGENCY INTRASTATE GAS, LLC VERSUS LOUISIANA TAX COMMISSION AND SCOTT MEREDITH, ASSESSOR OF CALDWELL PARISH

consolidated with A 1 2021 CA 0272 t

REGENCY INTRASTATE GAS, LLC l VERSUS V LOUISIANA TAX COMMISSION AND ROY ELROD, ASSESSOR OF FRANKLIN PARISH

consolidated with

2021 CA 0273

REGENCY INTRASTATE GAS, LLC VERSUS LOUISIANA TAX COMMISSION AND GLEN KIRKLAND, ASSESSOR OF JACKSON PARISH

Decision Rendered: SEP 2 7 2021

APPEALED FROM THE 19th JUDICIAL DISTRICT COURT, SECTION 24 EAST BATON ROUGE PARISH, LOUISIANA DOCKET NUMBERS 687, 353; 687, 354; 687, 355

HONORABLE DONALD JOHNSON, JUDGE

Angela W. Adolph Attorney for Plaintiff/Appellant Baton Rouge, Louisiana Regency Intrastate Gas, LLC

Brian A. Eddington Attorney for Defendant/ Appellees Baton Rouge, Louisiana Scott Meredith, Caldwell Parish Assessor; Rod Elrod, Franklin Parish Assessor; and Glen Kirkland, Jackson Parish Assessor

Robert D. Hoffman, Jr. Attorneys for Louisiana Tax Commission Drew Hoffman Baton Rouge, Louisiana

BEFORE: McDONALD, THERIOT, AND HESTER, 33. McDONALD, J.

In these consolidated cases, a taxpayer challenges the Louisiana Tax Commission' s

denial of the taxpayer's request for a reduction in the fair market value of the taxpayer's

pipeline property for tax year 2018 based on economic obsolescence. The taxpayer

appeals two district court judgments, which affirmed three Louisiana Tax Commission

decisions, which in turn affirmed three parish Board of Review decisions, which in turn

upheld the correctness of ad valorem property tax assessments by three parish assessors.

After review, we affirm one judgment, and affirm in part and vacate in part a second

judgment.

FACTUAL AND PROCEDURAL BACKGROUND

In 2018, Regency Intrastate Gas, LLC ( RIG) owned pipeline property that traversed

Caldwell, Franklin, and Jackson Parishes. When RIG filed its 2018 property tax returns in

these three parishes, it requested a 31. 04% reduction in its pipeline property's fair market

value based on economic obsolescence. Caldwell Parish Assessor Scott Meredith, Franklin

Parish Assessor Rod Elrod, and Jackson Parish Assessor Glen Kirkland ( the Assessors) each

denied RIG' s obsolescence reduction request.' The Caldwell, Franklin, and Jackson Parish

Boards of Review ( Boards of Review) 2 each rejected RIG' s challenge to the assessments.

RIG then appealed to the Louisiana Tax Commission ( LTC). After a hearing where the

parties presented documentary evidence and live testimony, the LTC issued three

decisions affirming the Boards of Review decisions upholding the Parish Assessors' 2018

assessments.

On September 3, 2019, RIG filed three petitions for judicial review of LTC' s

decisions in the district court, naming the LTC and the Assessors as defendants/ appellees.

The petitions were assigned Docket Number 687, 353 ( Caldwell suit); Docket Number

687, 354 ( Franklin suit); and, Docket Number 687, 355 ( Jackson suit). The Assessors filed

1 The Louisiana Tax Commission decisions note that the Caldwell Assessor applied a — 3. 97% reduction for obsolescence to RIG' s Canehill compressor station but applied no reduction for RIG' s Caldwell Parish -sited pipeline.

z The record shows the Caldwell, Franklin, and Jackson Parish Police Juries act as their respective parishes' Boards of Review when a taxpayer protests the Parish Assessors' property assessments. See La. R.S. 47: 1931; 47: 1992( B), ( C), and ( D); accord TBM- WC Sabine, LLC v. Sabine Parish Board of Review, 17- 1189 La. App. 3 Cir. 7/ 18/ 18), 250 So. 3d 1075, 1077, n. 2. 2 an unopposed motion to transfer and consolidate the proceedings, which the district court

granted. The administrative record was filed into the consolidated district court record,

the parties filed briefs, and the district court held a review hearing.

On October 20, 2020, the district court signed a judgment in favor of the LTC,

captioned with only the Caldwell suit docket number, against the " petitioner," denying and

dismissing the petition for judicial review ( October judgment). The October judgment

pertinently stated:

IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that the Court finds in favor of the appellee/ respondent, Louisiana Tax Commission, and against the petitioner. As such, the Petition for Judicial Review is DENIED. The court finds that the Commission' s decision was neither arbitrary nor capricious.

IT IS FURTHER ORDERED that the Petition for Judicial Review is hereby DISMISSED, at Petitioner' s costs.

The district court granted RIG' s motion for appeal from the October judgment, and

signed the order of appeal without the necessity for posting bond on November 20, 2020.

On December 4, 2020, the district court signed a second ' amended and restated"

judgment in favor of the LTC, captioned with the Caldwell, Franklin, and Jackson suit

docket numbers, adding that the judgment was also in favor of the Assessors, specifically

against RIG as the petitioner, and denying and dismissing RIG' s petitions for judicial

review ( December judgment). The December judgment pertinently stated:

IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that the Court finds in favor of Appellees/ Respondents, Caldwell Parish Assessor Scott Meredith, Franklin Parish Assessor Rod Elrod, Jackson Parish Assessor Glen Kirkland, and the Louisiana Tax Commission, and against the Appellant/ Petitioner, Regency Intrastate Gas, LLC. As such, the Petitions for Judicial Review are DENIED. The Court finds the Louisiana Tax Commission' s decisions were neither arbitrary nor capricious.

IT IS FURTHER ORDERED that the Petitions for [ Judicial] Review are hereby DISMISSED, at Petitioner's costs.

RIG also appealed from the December judgment, and the district court granted the

second appeal.

3 APPELLATE JURISDICTION

Louisiana Constitution article VII, § 18( E) provides that the correctness of

assessments by the assessor shall be subject to review first by the parish governing

authority, then by the LTC or its successor, and finally by the courts, all in accordance with

procedures established by law. See La. R. S. 47: 1931; 47: 1992; 47: 1989; 47: 1998.

Louisiana Revised Statutes 47: 1998 authorizes judicial review of the correctness of a tax

assessment, and the Administrative Procedure Act, specifically La. R. S. 49: 964( F) and ( G),

govern the extent of that review. La. R. S. 49: 967( A); D90 Energy, LLC V. Jefferson Davis

Parish Bd. of Review, 20- 00200 ( La. 10/ 20/ 20), So. 3d , 2020 WL 6145158,

5. When reviewing a final decision of an agency, the district court functions as an

appellate court. Blue Cube Operations, LLC v. Assumption Parish Bd. of Review, 20- 0157

La. App. 1 Cir. 11/ 6/ 20), 315 So. 3d 887, 890. An aggrieved party may obtain review of

any final judgment of the district court by appeal to the appropriate court of appeal. La.

R. S. 49: 965.

Although the district court functions as an appellate court in reviewing tax

assessments, certain procedural rules applicable to a district court sitting in its original

capacity also apply to a district court when it functions in an appellate capacity under La.

R. S. 49: 965. E.g., see Bennett v. Louisiana Department of Insurance, 20- 0666 ( La.

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Related

Herrera v. First National Insurance Co. of America
194 So. 3d 807 (Louisiana Court of Appeal, 2016)
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Regency Intrastate Gas, LLC v. Louisiana Tax Commission and Scott Meredith, Assessor of Caldwell Parish, Counsel Stack Legal Research, https://law.counselstack.com/opinion/regency-intrastate-gas-llc-v-louisiana-tax-commission-and-scott-meredith-lactapp-2021.