Swanek v. Lane County Assessor

CourtOregon Tax Court
DecidedDecember 28, 2022
DocketTC-MD 210089N
StatusUnpublished

This text of Swanek v. Lane County Assessor (Swanek v. Lane 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
Swanek v. Lane County Assessor, (Or. Super. Ct. 2022).

Opinion

IN THE OREGON TAX COURT MAGISTRATE DIVISION Property Tax

CATHY J. SWANEK, ) ) Plaintiff, ) TC-MD 210089N ) v. ) ) LANE COUNTY ASSESSOR, ) ORDER GRANTING DEFENDANT’S ) MOTION FOR SUMMARY Defendant. ) JUDGMENT

This matter came before the court on Defendant’s Motion for Summary Judgment

(Motion), filed September 21, 2022. Plaintiff filed her Response to Motion for Summary

Judgment (Response) on October 19, 2022. This matter is now ready for the court’s

determination.

I. STATEMENT OF FACTS, PARTIES’ POSITIONS

Plaintiff filed her Complaint on March 22, 2021, challenging the value of two parcels of

property, identified as Accounts 1205754 (lot 1202) and 1446879 (lot 1203) (subject properties)

for the 2020-21 tax year. (Compl at 1; Def’s Mot Summ J.) The 2020-21 tax roll real market

value (RMV) of Account 1205754 was $883,873 and the Board of Property Tax Appeals

(BOPTA) reduced it to $818,315. (Compl at 2.) Its maximum assessed value was $442,722.

(Id.) The 2020-21 tax roll RMV of Account 1446879 was $656,692; BOPTA found the same

value. (Compl at 3.) Its maximum assessed value was $341,367. (Id.) Plaintiff requests that the

assessed value and RMV of each lot be reduced to $370,000 and $290,000, respectively. (Compl

at 1.)

In a prior case, Plaintiff challenged the RMVs of the subject properties, for tax year

2019-20, arguing that their value had been significantly reduced by frequent shooting that

ORDER GRANTING DEFENDANT’S MOTION FOR SUMMARY JUDGMENT TC-MD 210089N 1 occurred on the neighboring Bureau of Land Management (BLM) land. Swanek v. Dept. of Rev.,

TC 5423, 2022 WL 2903990 at *1-2 (Or Tax July 22, 2022) (Swanek I). In addition, Plaintiff

requested that the court consider the subject properties for any exemption or special assessment

programs that they may be eligible for due to the shooting, including “act of God” relief. Id. at

*1. Finally, Plaintiff requested that the court exercise its equitable powers, either by reducing the

value of the subject properties or by creating a new class of special assessment for them. Id.

The court found that Plaintiff did not submit any competent evidence of value; instead, she

focused on criticizing the assessor’s appraisal report. Id. at *3-4. Plaintiff did not meet the

burden of proof on her RMV claim. Id. at *4. With respect to Plaintiff’s additional claims for

relief, the court found no supporting legal authority. Id. Plaintiff did not appeal from the

Swanek I opinion.

Defendant moves for summary judgment by reason of the court’s judgment denying

Plaintiff’s appeal in Swanek I. (Def’s Mot Summ J.) Defendant argues that “[w]ith rising

market values for residential property, the real market value for the 2020-21 tax year would be

higher than the BOPTA decision.” (Id.) Defendant requests that “the court dismiss this case, or

find an appropriate value that is reflective of the regular division decision, given known market

increases.” (Id.)

In response, Plaintiff continues to criticize the assessor’s appraisal report used in Swanek

I. (See Ptf’s Resp at 1 (“Appraisal Report used in [Swanek I] as evidence of RMV did not

include any comp[arable sales] with our 2 negative issues”).) Plaintiff takes similar issue with

the assessor’s refusal to consider the sale of a neighboring property as a comparable sale in its

appraisal report. (See id. at 2 (“Lan[e] County assessor/appraiser would not consider sale of

home adjacent to our property * * * as a comp[arable sale]. This property is more similar to our

ORDER GRANTING DEFENDANT’S MOTION FOR SUMMARY JUDGMENT TC-MD 210089N 2 property than those 20+ miles away”).) Plaintiff continues to maintain that she cannot find a

qualified appraiser to value the subject properties based on their unique features. (Id.) Plaintiff’s

primary goal appears to be some form of government protection, and until such protection is

provided, Plaintiff seeks a reduction in property taxes as an interim remedy. (See id. at 3 (“Until

Lane County and BLM correct the problem of shooting onto private property, at least property

taxes should be lowered to reflect the problem”).) 1

II. ANALYSIS

The issue is whether Defendant’s Motion for Summary Judgment should be granted.

Defendant’s Motion seeks dismissal of Plaintiff’s 2020-21 tax year appeal based on this

court’s opinion denying Plaintiff’s 2019-20 tax year appeal. “The general rule as to property tax

valuations is that each year stands by itself.” Mittleman v. Comm’n, 2 OTR 105, 106 (1965).

“[A] judicial determination of the value of real property for one year is not conclusive as to the

value of the property for a subsequent year.” Id. at 106-107. Notwithstanding the general rule,

the doctrine of issue preclusion may bar taxpayers from relitigating an issue “when an issue of

ultimate fact has been determined by a valid and final determination in a prior proceeding.”

Nelson v. Emerald People’s Util. Dist., 318 Or 99, 103, 862 P2d 1293 (1993). Issue preclusion

may apply if the following five requirements are met:

“1. The issue in the two proceedings is identical.

“2. The issue was actually litigated and was essential to a final decision on the merits in the prior proceeding.

“3. The party sought to be precluded has had a full and fair opportunity to be heard on that issue.

1 Plaintiff’s request for some form of government protection is outside of this court’s subject matter jurisdiction. See ORS 305.410(1) (2019) (tax court has jurisdiction over “questions of law and fact arising under the tax laws of this state”); see also Sanok v. Grimes, 294 Or 684, 698, 662 P2d 693 (1983) (taxpayer’s “tort claims are outside the jurisdiction of the tax court * * *”).

ORDER GRANTING DEFENDANT’S MOTION FOR SUMMARY JUDGMENT TC-MD 210089N 3 “4. The party sought to be precluded was a party or was in privity with a party to the prior proceeding.

“5. The prior proceeding was the type of proceeding to which this court will give preclusive effect.”

Id. at 104 (internal citations and footnote omitted).

Where the central issue is the same as it was in the prior proceeding and the taxpayer

does not present any new facts or issues when given the opportunity to do so, the first two

elements are satisfied. See Murray Family Trust v. Wasco Cty. Assessor, TC-MD 200132N,

2021 WL 237426 at *2 (Or Tax M Div Jan 25, 2021) (taxpayer sought to relitigate whether

property was an illegal lot of record). Here, Plaintiff asserts that the subject properties’ values in

the 2020-21 tax year were effectively reduced by the frequent shooting on the neighboring BLM

land; Plaintiff asserted the same position in her 2019-20 appeal. Plaintiff also refers to the sale

of an adjacent property as comparable; however, Plaintiff presented the same sale as evidence at

trial in her initial 2019-20 appeal in the Magistrate Division. See Swanek v. Lane Cty. Assessor,

TC-MD 200095N, 2021 WL 806954 at *1 (Or Tax M Div Mar 3, 2021) (“Plaintiff identified as a

comparable sale the neighboring house, which sold for $656,000 on July 31, 2020”) (internal

citations omitted). Finally, Plaintiff maintains there is no appraiser competent to value the

subject properties and, thus, does not plan to offer any new evidence of value.

Plaintiff continues to request some form of equitable relief; however, this issue was also

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Related

Nelson v. Emerald People's Utility District
862 P.2d 1293 (Oregon Supreme Court, 1993)
Sanok v. Grimes
662 P.2d 693 (Oregon Supreme Court, 1983)
Mittleman v. State Tax Commission
2 Or. Tax 105 (Oregon Tax Court, 1965)

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Swanek v. Lane County Assessor, Counsel Stack Legal Research, https://law.counselstack.com/opinion/swanek-v-lane-county-assessor-ortc-2022.