Armstrong-Trotwood, LLC v. State Tax Commission of MissouriAnnotate this Case
Appellants, who owned residential property located entirely in St. Louis County, argued that Jefferson and Franklin counties systematically undervalued property in those counties, causing Appellants to bear a disproportionate share of the cost of operating multi-county taxing districts. After exhausting their administrative remedies, Appellants filed a petition in the circuit court challenging their 2011-12 property tax assessments. The circuit court dismissed the petition for failing to state a claim upon which relief can be granted. The Supreme Court affirmed the dismissal of Appellants’ administrative claims for review and their claim for declaratory relief, holding (1) Appellants failed to assert a violation of the uniformity clause in article X, section 3 of the Missouri Constitution; and (2) the State Tax Commission lacked jurisdiction to hear Appellants’ claims of inter-county discrimination on appeal from the St. Louis County Board of Equalization.