Tiernan v. Feeney

CourtSuperior Court of Maine
DecidedAugust 30, 2016
DocketYORre-16-0037
StatusUnpublished

This text of Tiernan v. Feeney (Tiernan v. Feeney) 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
Tiernan v. Feeney, (Me. Super. Ct. 2016).

Opinion

STATE OF MAINE SUPERIOR COURT YORK, ss. Civil Action Docket No. AP-16-0037

TIBOR KORMENDY and IBOLYA KORMENDY,

Plaintiffs, MEMORANDUM OF DECISION v. AND ORDER

TOWN OF KENNEBUNK et al.,1

Defendants.

Tibor and Ibolya Kormendy filed this Rule 80B action seeking review of the

Kennebunk Board of Assessment Review's ("Board") November 4, 2016 denial of their

tax abatement appeal for the April l, 2015 assessment date. During the pendency of

this appeal plaintiffs also sought judicial review of Board actions on tax abatement

requests pertaining to the same property in other years. For the reasons that follow,

the court grants the appeal, in part, with respect to the November 4, 2016 denial and

remands to the Board for further proceedings; and denies all other requests because

they are untimely and the court lacks jurisdiction to hear them.

Background

Plaintiffs own a single-family residence located at 17 Tideview Terrace in the River

Bend Woods Subdivision on the Mousam River in Kennebunk, Maine. It is identified as

1 In addition to the Town of Kennebunk, the complaint names as a defendant the Kennebunk Board of Assessment Review, Daniel Robinson (Assessor), Megan Verlander (Assistant Assessor) and Barry Tibbetts (former Town Manager). The town itself is the only proper party defendant in a tax abatement proceeding. See Shawmut Inn v. Jnhabs. Of Town ofKennebunkport, 428 A.2d 384, 388 (Me. 1981); Tax Assessor of Town of Sebago v. D,ummond, 402 A.2d 469, 470 (Me. 1979); Assessors, Town of Bristol v. Eldridge, 392 A.2d 37, 39-40 (Me. 1978) .

1 Lot 4 on Tax Map 70 (the "Property"). (Def. Supp. R. 44-45.)2 Plaintiffs contend that the

topography of the Property mandates a lower assessment.

Plaintiffs first filed an application for ta.'C abatement in the winter of 2015-2016

with the Town Assessor. (Def. Supp. R. 77.) The Assessor denied the application by

letter on April 20, 2016. (Def. Supp. R. 77.) Plaintiffs appealed this decision to the Board

on June 14 of the same year, seeking a reduction in the assessed value of the Property

from $372,800 to $264,121. (Def. Supp. R. 2, 78, 85.) Plaintiffs included an appraisal

done by Priority Appraisal USA, LLC that valued the Property at $375,000 as of August

24, 2012. (Def. Supp. R. 8-24.)

Hearing on plaintiffs' appeal was originally scheduled for August 2, 2016 but the

Board sought to continue the hearing because its secretary and other staff were on

medical leave. (Def. Supp. R. 26.) Mr. Kormendy consented to extend the time for a

hearing until September 30, 2016. (Def. Supp. R. 28-29.) Mr. Kormendy inquired by

email on September 9, 2016 "if the postponed hearing could be now scheduled?" (Def.

Supp. R. 29). The Board secretary notified Mr. Kormendy by email on September 20,

2016 to inform him that a hearing had been re-scheduled for October 18, 2016; and the

town believes he apparently responded on September 27, 2017 that he was "not

available"3 to attend a meeting on that date. (Def. Supp. R. 82.) He had also emailed a

revised application to the Board the previous day "for our pending B.A.R. process." (Def.

Supp. R. 30-35.) The Board scheduled a hearing for November 1, 2016. (Def. Supp. R.

2The Town submitted "Defendants' Supplemental Rule 80B Record" (cited herein as "Def. Supp. R.") to complete the record before the court and remedy deficiencies in the record filed by plaintiffs. See Footnote 4, infra.

3 Mr. Kormcndy disputes this characterizatfon. At the November 1, 2016 hearing he stated: "[I] Rairl it was not acceptable, because it was past the deadline . . .. (T]hey have to follow the rules." (Def. Supp. R. 82.)

2 82.) Notice of the November !st hearing date was sent to Kormendy on September 29,

2016. (Def. Supp. R. 36-41.)

Plaintiffs did not respond to this notice. (Def. Supp. R. 82.) Instead, they filed

the instant action for governmental review on October 12, 2016, providing a copy of the

appeal to the Town Clerk. Id. By an October 26, 2016 email, Mr. Kormendy notified

the Board that he believed the Board lacked jurisdiction over his abatement appeal.

(Def. Supp. R. 43.) The Board responded to this email on October 27, 2016, stating that

it retained jurisdiction and that the hearing was still scheduled for November 1, 2016.

Id.

The Board went forward with the November 1, 2016 hearing. (R. 82.) Mr.

Kormendy appeared, presented a copy of a revised application, objected to the Board

conducting the hearing, and then left because he "did not want to jeopardize his court

action." (Def. Supp. R. 76-80, 82-84.) The Board reviewed the written submissions from

plaintiffs and the Town Assessor as well as hear oral testimony from the Assessor. (Def.

Supp. R. 44-75, 85-89.)

The Assessor testified about recent sales and listings supporting the value of the

Property as assessed. (Def. Supp. R. 88.) He addressed plaintiffs' argument regarding

the topography of the Property and testified that in dealing with small properties

abutting waterways it is the site location that gives the land value and not its slope

towards the water. Id. He testified that the appraisal performed by Priority Appraisal

USA, LLC valuing the Property at $375,000 was in line with the Property's $372,800

assessment. Id. The Assessor testified about the Town's assessment process, explaining

use of the town-wide revaluation performed for the April 1, 2003 assessment date as

the basis for the Town's current assessments and the changes that resulted from a re­

designation of river-front property. (Def. Supp. R. 44, 87) The change resulted in an

3 increase of the assessed value of plaintiffs' Property from $341,400 to $372,800 for the

April 1, 2013 assessment date. (Def. Supp. R. 44-48, 87.)4

Following deliberations, the Board voted unanimously to deny plaintiffs' appeal

and adopt its written decision. (Def. Supp. R. 90.} The decision outlines the basis for

the Board's conclusion that plaintiffs failed to prove a substantial overvaluation or that

the Property was subjected to unjust discrimination. (Def. Supp. R. 90.) The Board

found the Assessor's testimony credible and refused to find error in the assessment of

the Property. (Def. Supp. R. 90.)

Plaintiffs filed their brief and the record with the court on November 14, 2016.

The Town objected to the record as submitted by plaintiffs and subsequently filed the

supplemental record noted above and its opposing memorandum.5

Plaintiffs have made numerous filings with the court, including: a motion for a

trial of the facts, a motion for reimbursement for extra costs of service of process, a

motion for writ or injunction, a motion to vacate a 2013 tax increase, a motion to order

defendant to answer interrogatories, and a motion to suspend processing, all of which

were the subject of earlier court orders in the case. Plaintiffs also filed a motion for leave ,.. to amend pleadings, which the court granted on July 5, 2017. See Order on Pending : I i !

4 From April 1, 2003 until April 1, 2013, the Property was classified as Site Index "8." (Def. Supp. R.

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