AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• AMREP Southwest Inc. and its subsidiary, Outer Rim Investments, Inc., owned approximately 19,541 parcels of vacant property in Sandoval County, New Mexico. They protested the 2009 tax year valuations provided by the Sandoval County Assessor, arguing that the assessed values were greater than the fair market values. The protest focused on the refusal of the Sandoval County Valuation Protests Board to consider AMREP's comparable 2009 sales evidence, relying instead on 2008 sales data (paras 2-3).

Procedural History

• District Court of Sandoval County: Affirmed the Board's decision to rely exclusively on comparable 2008 sales data for property valuation (para 1).

Parties' Submissions

• Appellants (AMREP Southwest Inc. and Outer Rim Investments, Inc.): Argued that the Board's refusal to adjust valuations based on comparable 2009 sales was contrary to law, arbitrary, and denied them due process. They contended that their 2009 sales data was relevant and should have been considered under generally accepted appraisal techniques (paras 3, 6).
• Respondent (Sandoval County Assessor): Supported the Board's decision, arguing that the valuation was correctly based on data available as of January 1, 2009, in accordance with statutory and administrative code provisions. The Assessor maintained that the Board's interpretation was consistent with long-standing practice (paras 4, 6).

Legal Issues

• Whether the Board erred by refusing to consider comparable 2009 sales evidence for the valuation of property for the 2009 tax year (para 1).
• Whether the Board's interpretation of its governing statutes and administrative code provisions was contrary to law and whether it acted arbitrarily and denied AMREP due process by failing to consider the comparable 2009 sales data (para 6).

Disposition

• The Court of Appeals affirmed the decision of the District Court, holding that the Board did not err in its refusal to consider 2009 sales data for property valuation (para 19).

Reasons

• Per Jonathan B. Sutin, with concurrence from Celia Foy Castillo and Roderick T. Kennedy, the Court reasoned that the Board's decision was not arbitrary, capricious, or an abuse of discretion; it was supported by substantial evidence and in accordance with law. The Court found the Board's interpretation of statutory and administrative code provisions to be reasonable, emphasizing the policy-driven purpose of having a cut-off date for sales data to ensure consistency, efficiency, and effectiveness in the valuation process. The Court noted that the law does not require protest boards to consider comparable tax-year sales in determining valuation adjustments. The refusal to consider AMREP's 2009 sales data was based on a longstanding interpretation of the relevant statutory and administrative provisions, which was deemed not contrary to law, arbitrary, or a denial of procedural due process (paras 7-18).