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Keywords

statuteappealappellantappellee
statuteappealappellantappellee

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Straughn v. K & K Land Management, Inc., 326 So.2d 421

Facts

The appeal arose from a judgment by the Circuit Court of Polk County, which declared Section 193.461(4)(c), Florida Statutes, unconstitutional. The Tax Assessor, Rhoden, reclassified land owned by the appellee as non-agricultural, denying an agricultural assessment for 1973, which led to a significant tax increase. The statute in question established a presumption against agricultural use based on the sale price of the land compared to its agricultural assessment.

The appeal arose from a judgment by the Circuit Court of Polk County, which declared Section 193.461(4)(c), Florida Statutes, unconstitutional. The Tax Assessor, Rhoden, reclassified land owned by the appellee as non-agricultural, denying an agricultural assessment for 1973, which led to a significant tax increase.

Issue

Whether Section 193.461(4)(c), Florida Statutes, which creates a presumption that land sold for a price three times its agricultural assessment is not used primarily for bona fide agricultural purposes, is unconstitutional.

Whether Section 193.461(4)(c), Florida Statutes, which creates a presumption that land sold for a price three times its agricultural assessment is not used primarily for bona fide agricultural purposes, is unconstitutional.

Rule

The court applied the principle that statutory presumptions must have a rational connection between the fact proved and the ultimate fact presumed, and there must be a right to rebut the presumption in a fair manner.

The court applied the principle that statutory presumptions must have a rational connection between the fact proved and the ultimate fact presumed, and there must be a right to rebut the presumption in a fair manner.

Analysis

The court found that the statutory presumption established a rational basis for determining agricultural use based on the sale price of the land. It noted that the presumption could be rebutted by demonstrating 'special circumstances' that indicate the land is still used for bona fide agricultural purposes. The court emphasized that the statute does not violate constitutional requirements as it only affects the classification of property, not its assessment.

The court found that the statutory presumption established a rational basis for determining agricultural use based on the sale price of the land. It noted that the presumption could be rebutted by demonstrating 'special circumstances' that indicate the land is still used for bona fide agricultural purposes.

Conclusion

The Supreme Court reversed the lower court's judgment declaring the statute unconstitutional and remanded the case for further proceedings consistent with its opinion.

The Supreme Court reversed the lower court's judgment declaring the statute unconstitutional and remanded the case for further proceedings consistent with its opinion.

Who won?

The prevailing party was the appellants, Straughn and Rhoden, as the Supreme Court upheld the constitutionality of the statutory presumption.

The prevailing party was the appellants, Straughn and Rhoden, as the Supreme Court upheld the constitutionality of the statutory presumption.

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