Supervisor of Assessments of Baltimore County v. William Cardinal Keeler, Archbishop of Baltimore

Summary

The Maryland Court of Appeals considered whether 16.5 acres of open space within a 27-acre church property qualified for Maryland's property-tax exemption for property actually and exclusively used for public religious worship. The court affirmed the exemption, holding that the entire parcel could be viewed as an integrated whole where zoning restrictions and covenants limited the disputed acreage to open-space use supporting the church and prohibited commercial or residential development. The court also applied deferential substantial-evidence review to the Maryland Tax Court's factual findings.

Holdings

1. A portion of a church parcel restricted by zoning and covenants to open-space use may qualify for the religious-worship exemption when the parcel is used as an integrated whole to support religious worship, the restricted acreage has no nonchurch use, and the administrative finding that the entire parcel supports worship is supported by substantial evidence.
2. A reviewing court may reverse a Maryland Tax Court decision based solely on an erroneous legal conclusion, but must uphold factual determinations supported by substantial evidence and may not substitute its judgment for the agency's reasonable factual inferences.

Questions Presented

1. Whether 16.5 acres of undeveloped open space within a church's restricted 27-acre parcel were actually and exclusively used for public religious worship under Maryland Tax-Property Article § 7-204.
2. What standard of judicial review applies to the Maryland Tax Court's legal and factual determinations in a property-tax exemption case.

Disposition

affirmed