Athena Providence Place et al. v. Elyse M. Pare, in her capacity as Tax Assessor for the City of Providence, et al.

Summary

The Rhode Island Supreme Court consolidated appeals concerning property-tax assessments for condominium units in Providence after expiration of a tax stabilization agreement. The Court held that the city’s revaluation was not shown to be selective, arbitrary, or discriminatory and that the city complied with applicable statutory notice requirements. The Court reversed the Superior Court judgments and remanded for entry of judgments in favor of the city.

Holdings

1. The 2013 revaluation was not shown to be selective or discriminatory because the taxpayers failed to prove that The 903 was singled out for revaluation while similar properties were not.
2. Upon expiration of the tax stabilization agreement, the city was entitled and required to tax The 903 at its full and fair cash value, subject to compliance with statutory notice requirements and the prohibition against selective assessment.
3. The city complied with the statutory notice requirements for the 2013 revaluation and the 2014 and 2015 assessments.
4. The Superior Court clearly erred by finding that the revaluation was selective and discriminatory and by concluding that the taxpayers had been denied the benefits of a lawful revaluation.

Questions Presented

1. Whether the city's 2013 revaluation of The 903 was selective, arbitrary, discriminatory, illegal, or invalid.
2. Whether the city complied with the statutory notice requirements governing property-tax assessments and revaluations.
3. Whether the taxpayers met their burden of proving that The 903 was singled out for revaluation while similar properties were not.

Disposition

reversed_and_remanded