Illinois Fourth District Appellate Courthouse, Springfield, Illinois
SPRINGFIELD — An Illinois state appeals panel has ruled Sangamon County officials didn't violate the law by using different methodologies when valuing properties around Lake Springfield for property tax purposes, despite homeowners' contentions the methodology choices left them with higher tax bills, while awarding lower tax bills to boat clubs and other commercial properties around the same lake.
The case had landed in Sangamon County court in September 2017, when 13 owners of lakefront residential properties on Lake Springfield accused the county's assessors of not following legal requirements for uniform assessments.
The homeowners had filed complaints with the Sangamon County Board of Review from September 2016 to January 2017. They then jointly filed a tax objection complaint against the county collector in Sangamon County Circuit Court. That complaint alleged seven shoreline recreational clubs paid far less than they would’ve in property taxes had the county valued their land using the same formula applied to the residential parcels.
Judge John Madonia denied the homeowners’ February 2019 motion for summary judgment, but allowed them to amend the complaint that July. They did so, adding allegations the county hadn’t made a mistake or acted unofficially, but said their plight was “instead the intentional and designed result of a separate and far lower assessment formula” and further asserted their only contention was that using distinct “commercial” and “residential” formulas violated the state Constitution’s uniformity clause.
Madonia conducted a bench trial in August 2024 consisting entirely of reviewing evidence. That December he came down in favor of the homeowners, writing that “when evaluating and assessing these non-farm land, lakefront lots, without considering improvements, which both the assessors and plaintiffs’ expert testified was the appropriate way to fairly value the land-only portion of the property it is clear the lots are remarkably similar in characteristics.”
All the properties had residential zoning, Madonia noted, and for the club properties, leases with nonprofit corporations barred commercial business. He awarded damages to the homeowners based on the difference between their tax bills and what they would’ve paid had their assessed valuations been derived from the commercial formula.
The county challenged that ruling before the Illinois Fourth District Appellate Court. Justice David Vancil wrote the panel’s opinion, filed June 16; Justice Robert Steigmann concurred. Justice Eugene Doherty dissented. The order was issued under Supreme Court Rule 23, which restricts its use as precedent.
“To prove a disparity in taxation, plaintiffs must prove that their properties and the recreational club properties were each valued at different proportions of their (fair cash values),” Vancil wrote. “However, plaintiffs did not present any evidence of their properties’ FCVs or the FCVs of the recreational club properties. As a result, although two different formulas were used to assess the properties, it is impossible to determine if the use of the two different formulas actually resulted in plaintiffs paying taxes on a disproportionate percentage of their properties’ FCVs, as is required to show a violation of the uniformity clause.”
The homeowners pointed to a 1998 Tazewell County case, Walsh v. Property Tax Appeal Board, to argue cash value evidence isn’t needed because there is no dispute whether county officials used different formulas. Justice Doherty’s dissent accepted that argument, but Vancil said the majority found otherwise.
“The supreme court determined that Tazewell County’s use of (a) mass appraisal method violated the uniformity clause because it yielded assessed valuations that bore little relationship to true FCV,” Vancil wrote.
But it also said the county review board improperly used a recent sale price of a certain property to calculate its value while deferring to the mass method for other valuations. And, because courts had evidence of respective cash values, findings were definitive to a degree not possible regarding the Lake Springfield dispute.
“The dissent acknowledges that inaccurate valuations result in disparate taxation, which results in a uniformity clause violation,” Vancil wrote. “However, the dissent also interprets Walsh to find a separate basis for a uniformity clause violation: the use of different valuation methods alone. Notably, the dissent does not argue that the use of different valuation methods violates the uniformity clause because, as the court in Walsh stated, inaccurate valuations result in assessed values that are not aligned with true FCV. Instead, the dissent argues that the use of differing methods itself is sufficient to constitute a violation.”
While the majority agreed the homeowners would’ve paid less had their properties been subject to the commercial formula, it said they still didn’t show “they paid taxes on a larger proportion of their properties’ true value than the recreational club lots.” The panel also said the plaintiffs couldn’t make their argument regarding how the county assessed leasehold interests because they didn’t raise it in the amended complaint.
In his dissent, Doherty noted the issue isn’t whether assessments were accurate — he noted the Walsh plaintiffs conceded their assessment was accurate — because for a uniformity challenge “the basis for achieving the levels” of taxation are relevant.
However, the majority placed focus on “the results of the use of different valuation methods, not the use of the methods,” Vancil wrote. “It is possible, as plaintiffs argue, that the use of two different formulas here resulted in plaintiffs paying taxes on 33 1/3% of their properties’ FCVs while defendants paid taxes on a different, smaller percentage, or vice versa. However, by merely asserting that two different formulas were used to value the land of each property, plaintiffs have failed to prove this. Therefore, their uniformity clause claim must fail.”
