William and Teresa Poku v. Borough of Red Bank

CourtNew Jersey Tax Court
DecidedAugust 15, 2023
Docket07567-2022
StatusUnpublished

This text of William and Teresa Poku v. Borough of Red Bank (William and Teresa Poku v. Borough of Red Bank) 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
William and Teresa Poku v. Borough of Red Bank, (N.J. Super. Ct. 2023).

Opinion

NOT FOR PUBLICATION WITHOUT APPROVAL OF THE TAX COURT COMMITTEE ON OPINIONS

TAX COURT OF NEW JERSEY

MALA SUNDAR Richard J. Hughes Justice Complex PRESIDING JUDGE P.O. Box 975 Trenton, New Jersey 08625-0975 609 815-2922, Ext. 54630 Fax 609 376-3018

August 14, 2023

William K. and Teresa Poku Plaintiffs, Self-Represented

Daniel O’Hern, Esq. Byrnes, O’Hern & Heugle, LLC Attorney for Defendant

Re: Poku et al. v. Borough of Red Bank Block 81, Lot 20 Docket No. 007567-2022

Dear Mrs. & Mr. Poku and Counsel:

This opinion decides plaintiffs’ motion for reconsideration of this court’s Order dated April

14, 2023. For the reasons stated below, the motion is denied.

BACKGROUND

In its Order dated April 14, 2023, this court denied plaintiffs’ summary judgment motion

and granted defendant’s cross-motion for summary judgment dismissing certain counts of

plaintiffs’ complaint. The court held that (1) it lacks subject-matter jurisdiction to decide the merits

of plaintiffs’ allegation that defendant’s local property tax assessment on the above-referenced

property (“Subject”) for tax year 2022, and its assessments on all properties in the vicinity of the

Subject were racially discriminatory, and (2) relief under the Freeze Act for tax years 2018 through

2023 based on a final judgment of this court for tax year 2017, was statutorily unavailable. The

court however granted plaintiffs’ summary judgment motion in part by granting Freeze Act relief

1 for tax years 2018 and 2019 based on the 2017 final judgment. 1 The court denied plaintiffs’ request

for sanctions against defendant and stated that it “will issue a Case Management Order scheduling”

tax year 2022 “for trial as to the issue of valuation of the [Subject] along with tax year 2023.” 2

On May 6, 2023, plaintiffs moved for reconsideration. They argued that this court

“overlooked” the application of N.J.S.A. 54:3-26, which provides that the Freeze Act applies to

final judgments of a county board of taxation. They conceded that defendant is “correct that the

2017 value judgment cannot provide relief under the Freeze Act for tax year 2022,” however, they

stated, “it is a matter of public record that there was a value adjudication before” the Monmouth

County Board of Taxation (“MCBT”) “for the years 2020 through 2022.”

In a supplemental pleading filed on May 11, 2023, plaintiffs attached a judgment of the

MCBT for tax year 2019. That judgment dismissed plaintiffs’ petition under Code 5A, which

stands for “Dismissal with Prejudice, Non-appearance (lack of prosecution).” It also showed a

total (land plus improvement allocation) of $181,100 in both the “original assessment” column

and “judgment” column on the front page of the judgment. Plaintiffs did not appeal this judgment.

On May 18, 2023, defendant, the Borough of Red Bank (“Borough”) opposed plaintiffs’

reconsideration motion on grounds the court had correctly decided that (a) it lacked subject-matter

jurisdiction to decide plaintiffs’ race-based allegations, and (b) Freeze Act relief is unavailable for

1 This court had entered a judgment for tax year 2017 reflecting the assessment at $165,000 based on the parties’ settlement. That judgment was final and therefore, constituted a base year for purposes of the Freeze Act.

2 For tax year 2022, the Monmouth County Board of Taxation issued a judgment under Code 2B (“Presumption of correctness not overturned”), and thereby affirmed the assessment of $226,300. Plaintiffs appealed the judgment to this court, and thereafter filed their summary judgment motion. Therein, they asked the court to try the 2022 and the 2023 appeals together since they had also challenged the Subject’s 2023 assessment before the Monmouth County Board of Taxation. 2 tax year 2022. The Borough also noted that there is no other base year that would allow the Freeze

Act to apply to tax year 2022.

Subsequently, the court directed the parties to submit the MCBT’s judgments for other tax

years since plaintiffs alleged that they existed. Both parties claimed they were unable to find any

judgments. The court then located the MCBT judgment for tax year 2021 on the MCBT’s website.

That judgment was entered under Code 2B (“Presumption of correctness not overturned”) and

reflected a total (land plus improvement allocation) of $191,400 in both the “original assessment”

column and the “judgment” column on the front page of the judgment. The court provided the

same to the parties with an opportunity to supplement their respective pleadings to address the

effect of this judgment on plaintiffs’ claim for Freeze Act relief.

On July 10, 2023, the Borough supplemented its opposition contending that plaintiffs had

not “successfully prosecute[d]” their challenge to the 2021 assessment since “there was no

reduction in the assessed value in the 2021 [MCBT] judgment,” (relying on Seaboard v. Borough

of Penns Grove, 28 N.J. Tax 607, 618 (Tax 2015), which observed that “[t]he Freeze Act protects

taxpayers who have successfully prosecuted a challenge to an assessment on their property”). The

Borough also argued that since the MCBT’s judgment affirmed the 2021 assessment for plaintiffs’

failure to overcome its presumptive correctness, the judgment cannot serve as a base year for

purposes of the Freeze Act’s application.

On July 17, 2023, plaintiffs replied stating that they only wanted Freeze Act relief for tax

years 2020 through 2023, and did not desire to have a trial on valuation “when the 2021 base year

already establishes a value by law” since the “case is solely about the FREEZE ACT exclusively.”

They included the 2020 MCBT judgment which was entered under Code 2B and reflected a total

(land plus improvement allocation) of $186,700 in both the “original assessment” column and

3 “judgment” column on the front page of the judgment. Plaintiffs stated that their “application for

Freeze Act relief can also be granted at the discretion of the plaintiffs for tax year 2023 since there

is a 2021 trigger year in range.” 3 However, they argued, the Subject should be valued at $165,000

or even lower, and that if “the 2017 value is reduced even by a nominal amount due to the absence

of property improvements . . . the true value . . . would be $164,999 or less.” This, they claimed

can be easily achieved if the Borough settled with plaintiffs for a lower amount. 4

A summary of the tax years, the MCBT judgments, and their dispositions, are as follows:

Tax Year Assessment MCBT Judgment Judgment Code Tax Court 2017 $168,200 $168,200 2B Appeal Settled at $165,000 2018 $178,600 $178,600 Unknown (not attached to Appeal dismissed for non- Tax Court complaint) compliance with court rule 2019 $181,100 $181,100 5A - Non-appearance (lack No appeal of prosecution) 2020 $186,700 $186,700 2B No appeal 2021 $191,400 $191,400 2B No appeal 2022 $226,300 $226,300 2B Appeal Pending 2023 $243,300 $243,300 6A - Tax Court Pending Appeal Pending

ANALYSIS

Plaintiffs are correct that their reconsideration motion is of this court’s interlocutory Order.

The April 14, 2023, Order was not captioned as an Order and Final Judgment as to the issues

decided therein. Further, the Order stated that the court would try the valuation counts of each of

the complaints for tax years 2022 and 2023 at a later date.

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William and Teresa Poku v. Borough of Red Bank, Counsel Stack Legal Research, https://law.counselstack.com/opinion/william-and-teresa-poku-v-borough-of-red-bank-njtaxct-2023.