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Mason County Overtaxed, Inc. v. Mason County, 62 Wash.2d 677, 384 P.2d 352

Facts

In 1959, the Mason County assessor significantly increased the tax assessments on waterfront properties along Hood Canal, with some properties seeing increases as high as 4900%. Residents and taxpayers, organized as Mason County Overtaxed, Inc., challenged these assessments, claiming they were arbitrary and inequitable. They presented evidence of the dramatic nature of the increases and argued that the assessor's methods were flawed, while the assessor defended his actions by detailing his comprehensive approach to property valuation.

Came one day into this verdant place, the assessor of Mason County in 1958, and, struck by the wonder of it all, he did what any assessor would do, he promptly raised the taxes in this wonderland. It was not the increase, but rather its sudden and dramatic nature which invited this litigation, for the assessments increased with startling abruptness.

Issue

Did the Mason County assessor's property tax assessments for 1959 and 1960 constitute arbitrary and capricious over-valuation, warranting judicial intervention?

Did the Mason County assessor's property tax assessments for 1959 and 1960 constitute arbitrary and capricious over-valuation, warranting judicial intervention?

Rule

The assessor is required to determine the true and fair value of property based on market value, as defined by RCW 84.40.030, which mandates that all property be assessed at fifty percent of its true and fair value in money.

The statute requires ‘All property shall be assessed fifty percent of its true and fair value in money.’ RCW 84.40.030.

Analysis

The court analyzed the evidence presented by both parties, noting that the assessor had followed statutory requirements and employed a detailed methodology in assessing property values. The court found no convincing evidence that the assessments were arbitrary or capricious, as the assessor had conducted thorough inspections and market studies. The plaintiffs' claims were largely based on the dramatic increases in assessments rather than on evidence of over-valuation.

We think that the learned trial judge lucidly said this in his oral memorandum opinion, summing up at the close of the trial, when he said of the plaintiffs: ‘* * * They are faced first with the principle of law that when a public official has performed a public duty it will be presumed that he has done it right, and the burden is entirely upon the person who seeks to attack his action to prove that it is not right and that it is in fact wrong. That's the law. The other principle involved is that that burden has to be met by evidence that's convincing. If it's close, if there is doubt on the fact as to who may be right or wrong, the decision must be in favor of the public official's action.’

Conclusion

The court affirmed the trial court's dismissal of the plaintiffs' claims, concluding that the evidence did not support allegations of over-valuation or constructive fraud against the assessor.

The judgment is in all respects affirmed. The complaints against the assessor by the plaintiffs are without foundation.

Who won?

Mason County Assessor prevailed in the case because the court found that the assessor had acted within the bounds of the law and had not engaged in arbitrary or capricious conduct in determining property values.

The assessor sought to explain these increases in assessments and to meet the charges that they were arbitrary, capricious, and discriminatory, by proof that he had followed the direction of the statutes in making them.

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