First United Methodist Church, Pekin, Illinois v. The Department of Revenue and David Harris, in His Official Capacity as Director of the Department of Revenue

Summary

The Illinois Appellate Court, Fourth District, considers whether a single-family residence used by a church’s housing ministry qualifies for a 2021 property-tax exemption under the religious- and charitable-purpose provisions of the Illinois Property Tax Code. The Illinois Department of Revenue denied the exemption, while the circuit court reversed that decision and found the property exempt under the charitable-purpose provision. The appellate court addresses appellate jurisdiction, standards of review, and the statutory and constitutional requirements for charitable-use exemptions.

Holdings

1. The appellate court had jurisdiction because the Church's administrative-review action presented a single claim for the requested 2021 property-tax exemption, even though the Church advanced charitable and religious statutory grounds. The circuit court's failure to address the alternative religious ground did not make its judgment nonfinal.
2. Charis Place qualified for the charitable-purpose property-tax exemption under section 15-65 because the Church established that the property was owned and used for charitable purposes, was not operated for profit, served persons in need, imposed no impermissible obstacles to receiving charity, and was primarily used to provide reduced-cost transitional housing and related support.
3. The court did not decide whether Charis Place qualified for the religious-purpose exemption under section 15-40 because the charitable-purpose exemption independently resolved the case.

Questions Presented

1. Whether the appellate court had jurisdiction over the Department's appeal when the circuit court ruled on the charitable-purpose exemption but did not separately address the alternative religious-purpose exemption.
2. Whether the Church's use of Charis Place qualified for the charitable-purpose property-tax exemption under section 15-65 of the Illinois Property Tax Code and the Korzen factors.
3. Whether the property qualified for the alternative religious-purpose exemption under section 15-40 of the Illinois Property Tax Code.

Disposition

reversed