Washington Shopping Center, Inc. v. Washington Township

CourtNew Jersey Tax Court
DecidedApril 10, 2019
Docket005517-2016, 002869-2017,006408-2018
StatusUnpublished

This text of Washington Shopping Center, Inc. v. Washington Township (Washington Shopping Center, Inc. v. Washington Township) 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
Washington Shopping Center, Inc. v. Washington Township, (N.J. Super. Ct. 2019).

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NOT FOR PUBLICATION WITHOUT APPROVAL OF THE TAX COURT COMMITTEE ON OPINIONS

April 9, 2019

Lawrence S. Berger, Esq. Berger & Bornstein, LLC 237 South Street P.O. Box 2049 Morristown, New Jersey 07962

Martin Allen, Esq. DiFrancesco, Bateman, Kunzman, Davis, Lehrer & Flaum, P.C. 15 Mountain Boulevard Warren, New Jersey 07059

Re: Washington Shopping Center, Inc. v. Washington Township Docket Nos. 005517-2016, 002869-2017, and 006408-2018

Dear Mr. Berger and Mr. Allen:

This letter shall constitute the court’s opinion on plaintiff’s request to reopen the trial

record and compel testimony from defendant’s proposed testifying expert as a rebuttal witness.

For the reasons explained more fully below, plaintiff’s request to reopen the trial record

and compel testimony from defendant’s proposed testifying expert is denied.

I. Procedural History and Factual Findings

Washington Shopping Center, Inc. (“WSCI”) is the owner of the real property and

improvements located at 459-471 Route 31 South, Washington Township, Warren County, New Jersey. The property is identified on Washington Township’s municipal tax map as Block 75,

Lot 1 (the “subject property”).

The real property comprises a 22.84 acre rectangular shaped parcel located at the

intersection of Route 31 South and County Road 632. As of the valuation dates at issue, the real

property was improved with an 82,233 square foot retail center. The subject property also

includes a McDonald’s fast food restaurant located on a 0.9703 acre pad site, and two additional

undeveloped pad sites.

The subject property is located in Washington Township’s HC – Highway Commercial

District, permitting uses that include appliance stores, bakeries, banks, clothing stores, electronic

stores, furniture stores, grocery stores, hardware stores, liquor stores, medical and dental offices,

pet stores, pharmacies, restaurants, and theatres.

WSCI timely filed complaints challenging the subject property’s 2016, 2017, and 2018

tax year assessments. Washington Township timely filed a counterclaim for the 2018 tax year.

On April 11, 2018, the court entered a Case Management Order (“CMO”). The CMO

notified WSCI and Washington Township that if valuation of the subject property was at issue,

and either party intended to rely at trial upon the testimony of a valuation expert, then they shall

furnish each other with a trial-ready appraisal report by no later than August 13, 2018. 1

On or about November 28, 2018, WSCI served on Washington Township, and

Washington Township Served on WSCI, the appraisal reports of their proposed testifying

experts. WSCI served an appraisal report dated November 20, 2018, prepared by Gregg

1 Pursuant to the parties request, the court subsequently adjourned the date for the exchange of trial-ready appraisal reports twice, first to October 18, 2018, and then to November 28, 2018.

2 Manzione, MAI (“Mr. Manzione”) and Washington Township served an appraisal report dated

October 4, 2018, prepared by Darren Raymond, MAI (“Mr. Raymond”). 2

Trial was conducted on January 29, 2019. During trial, WSCI offered testimony from

Mr. Manzione, 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 real property valuation (the “expert”).

The expert prepared an appraisal report expressing an opinion of the market value of the subject

property as of the October 1, 2015, October 1, 2016, and October 1, 2017 valuation dates.

As of each valuation date, the subject property’s tax assessment, implied equalized value,

and the expert’s value conclusions are set forth below:

Valuation Tax Avg. ratio assessed Implied equalized Expert’s date Assessment to true value value concluded value 10/1/2015 $6,438,700 94.19% $6,835,864 $3,525,000 10/1/2016 $6,438,700 97.43% $6,608,539 $3,525,000 10/1/2017 $6,438,700 98.35% $6,546,721 $3,525,000

During trial, WSCI elicited evidence from the expert, who offered both factual and

opinion testimony about the subject property. See N.J.R.E. 702. WSCI shepherded the expert

through direct examination and following Washington Township’s cross-examination, conducted

a redirect examination of the expert. Following the expert’s testimony, WSCI requested the

court move the expert’s appraisal report into evidence. After affording the parties an opportunity

to be heard, the court moved the expert’s report into evidence. WSCI then advised the court that

2 In its transmittal letter to WSCI, Washington Township stated that Mr. Raymond’s report is “not intended to be, and should not be considered, adoptive admissions in accordance with Skibinki v. Smith, 206 N.J. Super[.] 349 (App. Div. 1985), and Sallo v. Sabatino, 146 N.J. Super[.] 416 (App. Div. 1976), certif[]. den[ied]., 75 N.J. 24 (1977)[.] . . . Please be advised that [Washington Township] reserve[s] the right not to introduce the report at the time of trial, and the report is being sent to you pursuant to Tax Court Practice, Custom, Procedure and Rules. The report should not be considered as part of evidence until, if and when the Township offers it into evidence.” See generally N.J.R.E. 803.

3 it rested, having presented all its affirmative proofs and evidence supporting a reduction in the

subject property’s local property tax assessment.

Immediately thereafter, Washington Township moved, under R. 4:37-2(b), for dismissal

of WSCI’s complaints. Washington Township argued that the expert’s opinion was a net

opinion, and that WSCI failed to overcome the presumption of validity that attaches to the

quantum of the local property tax assessment. After affording Washington Township and WSCI

an opportunity to be heard, the court denied Washington Township’s motion, placing a statement

of reasons on the record.

Washington Township then advised the court that, pursuant to R. 8:3-9, it was

withdrawing the counterclaim filed against WSCI for the 2018 tax year. Additionally,

Washington Township advised the court that it rested without introducing or offering any proofs

or evidence in these matters, including any testimony from Mr. Raymond, relying instead on the

validity of the subject property’s local property tax assessments.

The court then assigned dates for the submission of post-trial briefs and reply briefs.

However, thereafter WSCI raised with the court the prospect of seeking to call or compel

Washington Township’s proposed testifying expert, Mr. Raymond, as a rebuttal witness.

Although no testimony or evidence was offered by Washington Township in defense of the

subject property’s local property tax assessments, WSCI’s counsel sought to solicit or compel

rebuttal testimony from Mr. Raymond. 3

3 WSCI did not argue during trial, and does not argue in its request for relief, that Mr. Raymond’s appraisal report constituted an adoptive admission by Washington Township under N.J.R.E. 803(b)(2), and could have been read into the record. See Skibinski, 206 N.J. Super. at 354; see also Sallo, 146 N.J. Super. 418-419; Ratner v. General Motors Corp., 241 N.J. Super. 197, 201 n.2 (App. Div. 1990); Corcoran v. Sears Roebuck and Co., 312 N.J. Super. 117 (App, Div. 1998); Mehalick v. Schwartz, 223 N.J. Super. 259 (Law Div. 1987). However, based on the record, the court concludes that Mr.

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Washington Shopping Center, Inc. v. Washington Township, Counsel Stack Legal Research, https://law.counselstack.com/opinion/washington-shopping-center-inc-v-washington-township-njtaxct-2019.