Jake Zimmerman, Assessor, St. Louis County, Missouri Missouri Cases

The St. Louis County Assessor appealed the circuit court's judgment, which had reversed the Missouri State Tax Commission's (STC) decision denying commercial property owners' discrimination claims. The Missouri Supreme Court vacated the circuit court's judgment and reinstated the STC's decision. The Court held that the actual assessment level for ratio discrimination claims is based on the assessed value that determines the property owner's actual tax liability, including reductions ordered by the Board of Equalization (BOE) or STC, thereby overruling *Zimmerman v. Mid-America Fin. Corp.* The Court also found the STC's findings on sales chasing and regressive assessments were supported by substantial evidence and that the STC did not abuse its discretion in denying discovery requests.

Jake Zimmerman, Assessor for St. Louis County, appealed the circuit court's judgment that reversed the State Tax Commission's (STC) order concerning property tax assessments. Commercial property owners (Taxpayers) alleged discriminatory assessments after the 2017 reassessment. The circuit court had found the STC erred and remanded for retrial with directions. The appellate court reversed the circuit court, holding that the STC's decision rejecting the Taxpayers' discrimination claims was supported by competent and substantial evidence and that the STC did not abuse its discretion in discovery rulings, thereby reinstating the STC's original order.

Taxpayers, who successfully appealed their real estate tax valuations, sought reimbursement for attorney fees and appraisal costs. These costs were paid by a third-party property tax agent (PAR) under a contingency fee agreement, not directly by the Taxpayers. The circuit court awarded the fees, reversing the State Tax Commission's (STC) denial. The appellate court reversed the circuit court's judgment, holding that the relevant statute and ordinance, strictly construed as waivers of sovereign immunity, require a taxpayer to have actually incurred or paid the expenses to be eligible for "reimbursement." The case was remanded with instructions to reinstate the STC's order denying fees.

Property owners successfully appealed tax valuations and sought reimbursement for attorneys' fees and appraisal costs from the St. Louis County Assessor. The circuit court reversed the State Tax Commission's denial of reimbursement, reinstated a prior order granting fees, and found the owners were entitled to additional fees, the amount of which was to be determined later, certifying the judgment as final under Rule 74.01(b). The appellate court, reviewing its jurisdiction sua sponte, dismissed the appeal, holding that the judgment was not final and appealable because the amount of additional attorneys' fees, arising from the same claim, remained unresolved.