Trask v. Meade Cty. Comm'n

943 N.W.2d 493, 2020 S.D. 25
CourtSouth Dakota Supreme Court
DecidedMay 6, 2020
Docket28732
StatusPublished
Cited by4 cases

This text of 943 N.W.2d 493 (Trask v. Meade Cty. Comm'n) is published on Counsel Stack Legal Research, covering South Dakota Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Trask v. Meade Cty. Comm'n, 943 N.W.2d 493, 2020 S.D. 25 (S.D. 2020).

Opinion

#28732-a-MES 2020 S.D. 25

IN THE SUPREME COURT OF THE STATE OF SOUTH DAKOTA

****

PATRICK and ROSE MARY TRASK, Appellants,

v.

MEADE COUNTY COMMISSION, ACTING AS MEADE COUNTY BOARD OF EQUALIZATION, and the MEADE COUNTY DIRECTOR OF EQUALIZATION, Appellees.

APPEAL FROM THE CIRCUIT COURT OF THE FOURTH JUDICIAL CIRCUIT MEADE COUNTY, SOUTH DAKOTA

THE HONORABLE GORDON D. SWANSON Retired Judge

JAMES P. HURLEY of Bangs, McCullen, Butler, Foye & Simmons, LLP Rapid City, South Dakota Attorneys for appellants.

KENNETH L. CHLEBORAD of Office of the Meade County State’s Attorney Sturgis, South Dakota Attorneys for appellees.

CONSIDERED ON BRIEFS APRIL 29, 2019 OPINION FILED 05/06/20 #28732

SALTER, Justice

[¶1.] Patrick and Rose Mary Trask challenged the valuation of their

agricultural land before the Meade County Commission sitting as a board of

equalization (the Board), arguing the director of equalization incorrectly applied

statutory provisions to determine the land’s production value. After the Board

granted only partial relief, the Trasks appealed to the circuit court, which affirmed

the board’s assessed value of their property. The Trasks now appeal the circuit

court’s decision. We affirm.

Background

[¶2.] Patrick and Rose Mary Trask (the Trasks) farm and ranch 11,091

acres of land in southern Meade County. Patrick testified that he has lived and

worked on this land his whole life, and with Rose Mary since 1975. The Trasks are

predominantly cattle ranchers, but they also grow hay and alfalfa on portions of

their property to feed their cattle.

[¶3.] The assessed value of the Trasks’ ranch for 2016 was initially

calculated as $539 per acre. However, before mailing the tax assessment to the

Trasks, Kirk Chaffee, the director of equalization for Meade County, made

discretionary adjustments that reduced the assessment to an average of $519 per

acre.

[¶4.] The Trasks appealed this valuation to the Board. Following

arguments from the Trasks, the Board further adjusted the assessment down to an

average of $512 per acre. The Trasks, nevertheless, appealed the Board’s decision

to circuit court.

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[¶5.] The circuit court conducted a trial de novo during which the Trasks

acknowledged that the statutory method of assessment requires a determination of

their land’s “agricultural income value on a per acre basis.” SDCL 10-6-33.28.

However, they argued that the assessed value for their land was artificially high

because it failed to account for how the land is actually used. Patrick testified that

he believed 23% of his property should be classified as cropland and 77% should be

classified as noncropland. However, Chaffee and the Board (collectively, the

Appellees) determined that the Trasks’ property is comprised of 61% cropland and

39% noncropland based upon soil classifications Chaffee is obligated to use. Though

he cannot change the soil classification for agricultural land, Chaffee testified he

can make valuation adjustments based on the unique characteristics of the land to

“fine-tune[]” the valuation and ensure the county-wide assessment is “consistent

and fair.”

[¶6.] The circuit court affirmed the Appellees’ tax assessment of the Trasks’

property, finding that Chaffee “fully complied with the statutory mandates for

assessing agricultural property” and “appropriately took discretionary adjustments

as allowed by the statutory scheme for assessing agricultural property.” The court

further found that the Trasks had not shown that their 2016 tax assessment was

“unjust or inequitable” because the assessed valuation of their property did not

exceed its actual value and the Appellees had uniformly applied discretionary

adjustments to all Meade County agricultural property.

[¶7.] The Trasks raise several issues on appeal, which we consolidate and

restate as follows:

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1. Whether the circuit court erred when it determined that the Appellees complied with statutory provisions for valuing agricultural land in their 2016 assessment of the Trasks’ property.

2. Whether the circuit court erred when it determined that the Appellees’ 2016 tax assessment of the Trasks’ property did not violate provisions of the South Dakota Constitution that require uniform taxation at no more than its actual value.

Standard of Review

[¶8.] “The interpretation . . . and . . . application of statutes to given facts is

a question of law (or a mixed question of law and fact) that we review de novo.”

Smith v. Tripp Cty., 2009 S.D. 26, ¶ 10, 765 N.W.2d 242, 246. We review “[a]n

appeal asserting a violation of a constitutional provision [a]s a question of law.”

Stehly v. Davison Cty., 2011 S.D. 49, ¶ 7, 802 N.W.2d 897, 899. “Under the de novo

standard of review, we give no deference to the [circuit] court’s conclusions of law.”

Id. (quoting In re Guardianship of S.M.N., 2010 S.D. 31, ¶ 10, 781 N.W.2d 213,

218).

Analysis

Assessed Value of Agricultural Land

[¶9.] In 2008, the Legislature substantially revised the method of valuing

agricultural land for taxation by moving from a market-value approach to a

productivity-based model. See SDCL 10-6-33.28 (advising that “beginning on July

1, 2009, agricultural land shall be assessed based on its agricultural income value

on a per acre basis”). We have not previously considered a taxpayer challenge

under the new agricultural valuation model, codified at SDCL 10-6-33.28 to 10-6-

33.37.

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[¶10.] The essence of the change is reflected in the text of SDCL 10-6-33.28,

which institutes the term “agricultural income value” and broadly requires that

valuation “be determined on the basis of productivity and the annual earnings

capacity of the agricultural land.” The statute also provides a method for

calculating agricultural income value, which is defined as “the capitalized annual

earning capacity on a per acre basis . . . adjusted by an amount that reflects the

landowner’s share of the gross return.” Id. To determine capacity in this regard,

cropland and noncropland is considered separately:

The capacity of cropland to produce agricultural products shall be based on the income from crops or plants produced on the land. The capacity of noncropland to produce agricultural products shall be based on cash rents or the animal unit carrying capacity of the land, or a combination of both.

Id.

[¶11.] To account for the cost of planting a crop, the annual earning capacity

for cropland is identified as “thirty-five percent of the annual gross return to the

land,” while noncropland is calculated at “one hundred percent of the annual gross

return to the land based on cash rent . . . .” Id. For both types of agricultural land,

“the annual earning capacity shall be capitalized at a rate of six and six-tenths

percent to determine the agricultural income value.” Id.

[¶12.] The Legislature placed the responsibility for determining the

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Cite This Page — Counsel Stack

Bluebook (online)
943 N.W.2d 493, 2020 S.D. 25, Counsel Stack Legal Research, https://law.counselstack.com/opinion/trask-v-meade-cty-commn-sd-2020.