Roque Island Gardner Homestead Corp. v. Town of Jonesport

CourtSuperior Court of Maine
DecidedJune 3, 2020
DocketKENcv-19-28
StatusUnpublished

This text of Roque Island Gardner Homestead Corp. v. Town of Jonesport (Roque Island Gardner Homestead Corp. v. Town of Jonesport) 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
Roque Island Gardner Homestead Corp. v. Town of Jonesport, (Me. Super. Ct. 2020).

Opinion

(

STATE OF MAINE SUPERIOR COURT KENNEBEC, ss. CIVIL ACTION DOCKET NO. CV-19-28

ROQUE ISLAND GARDNER HOMESTEAD CORPORATION, Petitioner

v. DECISION AND ORDER (M.R. Civ. P. 80C) TOWN OF JONESPORT, Respondent

INTRODUCTION Roque Island Gardner Homestead Corporation ("RIGHC") has filed a Petition for Judicial Review pursuant to 5 M.R.S. §§ 11001-11008 (Maine Administrative Procedure Act) and M.R.Civ.P. 80C, from a Decision of the State Board of Property Tax Review ("State Board") dated May 15, 2019, which denied its appeal from the refusal of the Town of Jonesport to grant an abatement of its property taxes. This case involves the application and interpretation of lvlaine's Farm and Open Space Tax Law. Accordingly, it is helpful to an understanding of this dispute to begin with an examination of that statutory property tax program. THE STATUTORY FRAMEWORK The Constitution of lvlaine generally provides: "All taxes upon real ... estate shall be apportioned and assessed equally according to the just value thereof." Art. IX, sect. 8, Me. Const. Notwithstanding this general rule, however, the Constitution authorizes the Legislature to provide for the assessment of certain types of real estate "in accordance with a valuation based upon the current use thereof and in accordance with such conditions as the Legislature may enact." Among the types

Page 1 of 16 of real estate that may be so assessed are: "Farms and agricultural lands, timberlands and woodlands." Art. IX, sect. 8(2)(A), Me. Const. In 1971, the Legislature enacted the Maine Farm and Open Space Land Law. See P.L. 1971, c. 548 - 36 M.R.S. §§585-594. That law was repealed and replaced in 1975 with the Farm and Open Space Tax Law (hereinafter "Farmland Tax Law"). 36 M.R.S. §§ 1101-1121 as enacted by P.L. 1975, c. 726. As pertinent to property classified as "farmland," which is what this case is about, the stated purposes of this law are "to encourage the preservation of farmland ... in order to maintain a readily available source of food and fann products close to the metropolitan areas of the State,... [and] to prevent the forced conversion of fannland ... to more intensive uses as the result of economic pressures caused by the assessment thereof for purposes of property taxation at values incompatible with their preservation as such fannland ... .'' 36 M .R.S. § 1101 The term "farmland" is defined to mean: any tract or tracts of land, including woodland and wasteland, of at least 5 contiguous acres on which fanning or agricultural activities have contributed to a gross annual farming income of at least $2,000 per year from the sales value of agricultural products as defined in Title 7, section 152, subsection 2 in one of the 2, or 3 of the 5, calendar years preceding the date of application for classification. The farming or agricultural activity and income derived from that activity may be achieved by either the owner or a lessee of the land. 36 lvl.R.S. §1102(4). An owner of farmland may apply for taxation under the Farmland Tax Law

by submitting a signed schedule on or before April 1st of the year the owner wishes

to first subject the land to taxation under the law. 36 M.R.S. §§1103 & 1109(1). The application or schedule must be submitted to the municipal assessor on a form prescribed by the State Tax Assessor, and must show the location of the land in each classification (e.g., forested land, orchard land, pasture land, horticultural land). 36

Page 2 of 16 M.R.S. § 1109(1). There are a number of factors the assessor may consider in deciding whether land is farmland as defined. Id. If it is determined that the land is farmland, "the assessor shall classify it as farmland and apply the appropriate 100% valuations per acre for farmland and that land is subject to taxation under this

subchapter." 1 Id. The assessor is obligated by statute to notify the applicant/landowner on or

before June pt whether the application has been accepted or denied and, if denied,

the assessor must give the reasons for the denial and allow the owner to amend the schedule. 36 M.R.S. §1109(4). The assessor has considerable authority to investigate to obtain information about the application, including entering upon the land, propounding interrogatories to the owner and requiring the owner to appear before the assessor to answer questions. Id. Title 36 M.R.S. § 1105 directs the assessor to "establish the 100% valuation per acre based on the current use value of farmland used for agricultural or horticultural purposes." In arriving at such current use values, section 1119 of the Farmland Tax Law provides for the Department of Agriculture, Conservation and Forestry, in conjunction with the Bureau of Revenue Services, representatives of municipal assessors and farmers, to "prepare guidelines to assist local assessors in the valuation of farmland," that ''must include recommended values for cropland, orchard land, pastureland and horticultural land, differentiated by region where

justified ." 2

, The municipal assessor is also required to keep a record of the value of the farmland "and the value at which the farmland would have been assessed had it not been classified under this subchapter ." 36 M.R.S. § 1109(1). • Any variation from the recommended guidelines must be substantiated by the local assessor. 36 M.R.S. §1119.

Page 3 of 16 The values for farmland "may not reflect development or market purposes other than agricultural or horticultural use." 36 M.R.S. § 1105. The valuation for fann woodland within a farmland parcel is to be established by county and by forest type under the Tree Growth Tax Law. Id. citing 36 M.R.S. §§571-584-A. Section 1105 of the Famtland Tax Law concludes by stating: "Areas other than woodland, agricultural land or horticultural land located within any parcel of farmland classified under this subchapter are valued on the basis of just value." For the purpose of assessing taxes, 36 M.R.S. §1108(1) directs assessors to "adjust the 100% valuation per acre for farmland for their jurisdiction by whatever ratio or percentage of current just value is then being applied to other property within the municipality to obtain the assessed values." Section 1108(1) further mandates that "the classified farmland value must reflect only the current value for farm ... purposes and may not include any increment of value reflecting development pressure." The property tax rate for fannland property must be the same rate applicable to other property in the municipality. Id. FACTUAL AND PROCEDURAL BACKGROUND RIGHC is a Maine non-profit homestead corporation that owns Roque Island, Marsh Island and Bar Island in Mason's Bay within the municipality of Jonesport ("the Town"). 3 On January 17, 2017, RIGHC applied to the Town for farmland classification for Marsht Bar and Roque Islands in accordance with the Farmland

'The State Board has been involved with property tax issues with RIGHC and the Town on at least one previous occasion. In RIGHC v. Town of Jonesport, No. 2016-003 (BPTR, May 18, 2017), the State Board held that al! three islands were contiguous, thereby allowing Bar and Marsh Islands, when combined with Roque Island, to meet the 5-acre minimum threshold necessary to qualify for classification as "farmland" under the Farmland Tax Law. 36 M.R.S. § 1102(4) (Administrative Record, "A.R." at 16). The court understands that the State Board's decision was a divided one and ultimately led to the enactment of P.L. 2017, c. 183 by the Legislature. See 36 M.R.S. § 1102(4)(C). That section of the law addresses the subject of when a parcel of land on an island may be considered as being contiguous with a parcel of land on a different island. That legislation has no effect on this litigation.

Page 4 of 16 Tax Law for the 2017 tax year. (AR at 36).

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Bluebook (online)
Roque Island Gardner Homestead Corp. v. Town of Jonesport, Counsel Stack Legal Research, https://law.counselstack.com/opinion/roque-island-gardner-homestead-corp-v-town-of-jonesport-mesuperct-2020.