St. Elizabeth Hospital/Trinitas Healthcare Corp. v. City of Elizabeth

CourtNew Jersey Tax Court
DecidedMay 14, 2018
Docket015624-2011, 015248-2012, 014042-2013, 013679-2014, 013239-2015
StatusUnpublished

This text of St. Elizabeth Hospital/Trinitas Healthcare Corp. v. City of Elizabeth (St. Elizabeth Hospital/Trinitas Healthcare Corp. v. City of Elizabeth) is published on Counsel Stack Legal Research, covering New Jersey Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
St. Elizabeth Hospital/Trinitas Healthcare Corp. v. City of Elizabeth, (N.J. Super. Ct. 2018).

Opinion

TAX COURT OF NEW JERSEY

Joshua D. Novin Washington & Court Streets, 1st Floor Judge P.O. Box 910 Morristown, New Jersey 07963 Tel: (609) 815-2922, Ext. 54680 Fax: (973) 656-4305

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE TAX COURT COMMITTEE ON OPINIONS

May 11, 2018

Bruce J. Stavitsky, Esq. Stavitsky & Associates, LLC 350 Passaic Avenue Fairfield, New Jersey 07004

Robert D. Blau, Esq. Blau & Blau 223 Mountain Avenue Springfield, New Jersey 07081

Re: St. Elizabeth Hospital/Trinitas Healthcare Corp. v. City of Elizabeth Docket Nos. 015624-2011, 015248-2012, 014042-2013, 013679-2014 and 013239-2015

Dear Mr. Stavitsky and Mr. Blau:

This letter constitutes the court’s opinion following trial of local property tax appeals filed

by plaintiff, St. Elizabeth Hospital/Trinitas Healthcare Corp. (“St. Elizabeth Hospital”). St.

Elizabeth Hospital challenges the 2011, 2012, 2013, 2014, and 2015 tax year assessments on its

improved property located in the City of Elizabeth (“Elizabeth City”).

For the reasons stated more fully below, the court reduces the 2011 tax year assessment

and affirms the 2012, 2013, 2014, and 2015 tax year assessments.

I. Procedural History and Findings of Fact

St. Elizabeth Hospital is the owner of the real property and improvements located at 242-

260 Williamson Street, Elizabeth, New Jersey. The property is identified on Elizabeth City’s tax

1 map as Block 6, Lot 1653 (the “subject property”). The subject property is a rectangular-shaped,

1.2778 acre lot, located on the campus of the St. Elizabeth Hospital/Trinitas Regional Medical

Center. The site is improved with a masonry and steel five-story medical arts building, constructed

in 1994 (the “medical arts building”). The subject property also contains a portion of a four-story

public parking deck constructed in 1994. 1 Parking for the medical arts building is provided by the

attached four-story public parking deck.

The medical arts building is attached, on the westerly side, to the Trinitas Regional Medical

Center and attached, on the easterly side, to the four-story public parking deck. The medical arts

building contains a gross floor area of approximately 65,860 square feet, and a leasable area of

51,101 square feet. 2 As of the October 1, 2010 and October 1, 2011 valuation dates, the medical

arts building consisted of twenty-seven offices. As of the October 1, 2012, October 1, 2013, and

October 1, 2014 valuation dates, the medical arts building consisted of twenty-eight offices. One

of the offices is a retail pharmacy, offering a walk-up window.

The subject property is located in Elizabeth City’s R-4 Elevator Apartment district with

permitted uses that include single-family, two-family, and three to four-family dwellings, garden

apartments, and multifamily dwellings. The R-4 Elevator Apartment district does not permit

medical offices. Therefore, operation of the property as medical office building is a

1 During direct examination St. Elizabeth Hospital’s appraiser testified that the parking deck was not located on the subject property. However, during cross-examination St. Elizabeth Hospital’s appraiser changed his testimony, concluding instead that a portion of the parking deck, which he estimated at 50%, is located on the subject property. 2 St. Elizabeth Hospital’s appraiser estimated the leasable area of the medical arts building to be 50,238 square feet. The expert derived his estimated leasable area from the December 31, 2015 rent roll and discussions with the property manager. However, cross-examination revealed two discrepancies in the leasable area between the December 31, 2015 rent roll and a May 26, 2016 rent roll prepared by St. Elizabeth Hospital’s property manager. The May 26, 2016 rent roll states that the medical arts building consists of 51,101 square feet of leasable area. A review of the May 26, 2016 rent roll disclosed that unit 304 consists of 2,302 square feet and unit 406 consists of 883 square feet. Conversely, the December 31, 2015 rent roll stated that unit 304 consists of 1,484 square feet and unit 406 consists of 838 square feet. The court’s review of the April 1, 2016 Lease Agreement for unit 304 confirms that it consists of a leasable area of 2,302 square feet. Accordingly, the court finds the leasable area of the medical arts building to be 51,101 square feet.

2 nonconforming, legally permitted use. The subject property is located in the X Flood Hazard Zone,

denoting an area of minimal flooding risk.

For the 2011, 2012, 2013, 2014, and 2015 tax years, the subject property bore the following

tax assessment:

Land: $ 67,900 Improvement: $716,900 Total: $784,800

The average ratio of assessed to true value, commonly referred to as the Chapter 123 ratio, for

Elizabeth City is 11.80% for the 2011 tax year, 12.88% for the 2012 tax year, 13.35% for the 2013

tax year, 13.88% for the 2014 tax year, and 13.21% or the 2015 tax year. See N.J.S.A. 54:1-35a(a).

When the average ratio is applied to the tax assessment, the implied equalized value of the subject

property is $6,650,847 for the 2011 tax year, $6,093,168 for the 2012 tax year, $5,878,652 for the

2013 tax year, $5,654,179 for the 2014 tax year, and $5,940,954 for the 2015 tax year.

At trial, St. Elizabeth Hospital offered testimony from a State of New Jersey certified

general real estate appraiser, who was accepted by the court, without objection, as an expert in the

field of property valuation (the “expert”). In the expert’s opinion, the subject property’s

neighborhood is “defined by” the Trinitas Regional Medical Center. According to the expert, the

“Trinitas Hospital is the main source of business for our building and it’s the main economic

influence for this building as well. It really does dominate this particular portion of the City of

Elizabeth.” The expert further expressed that the medical arts building’s “location adjacent to a

hospital is a major benefit. . . .” Therefore, the expert concluded that the medical arts building is

“an institutionally invested type of property, a premier property. . . .”

During the tax years at issue, the medical arts building was managed by a property

management firm. Due, in part, to the diligence of the property manager and the medical arts

3 building’s attractiveness to medical professionals in the Elizabeth and Union County marketplaces,

during the tax years at issue the medical arts building experienced a very low vacancy rate.

Although the expert did not calculate its actual vacancy rate, the court’s review of the rent rolls for

the tax years at issue disclosed that all units were either fully occupied, or vacant for only brief

periods of time before being re-let. The medical arts building tenants consist of physicians and

other medical-related professionals who are affiliated with Trinitas Regional Medical Center. Any

tenant seeking to lease office space in the medical arts building must be “on the hospital medical

staff at Trinitas Hospital” and must agree to “comply with the religious covenants of Trinitas

Hospital. . . .” All leases are either gross or modified gross, where St. Elizabeth Hospital bears

responsibility for all real estate taxes, insurance, security, repairs, maintenance, and utilities.

The expert prepared an appraisal report expressing his opinion of the true value of the

subject property as of the October 1, 2010, October 1, 2011, October 1, 2012, October 1, 2013,

and October 1, 2014 valuation dates.

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