Riverside Owner v. City of Richmond

The City of Richmond provides a partial exemption from real estate taxes for qualifying rehabilitated property if a property increases in value by at least forty percent because of rehabilitation. According to the city code, the amount of the partial exemption is the difference between the property's assessed value before rehabilitation and its initial rehabilitated assessed value. At issue in this case was whether the City Assessor's policy of determining a property's initial rehabilitated assessed value not as of the date its rehabilitation is completed but as of the date its owner's application for the program is submitted was consistent with the requirements of the city code. The circuit court held the policy departed from the requirements of the code because the ordinance requires that a property's first assessed value after rehabilitation be used to determine the amount of a partial exemption. The Supreme Court affirmed, holding that "initial rehabilitated assessed value" means the first assessed value after rehabilitation and not, as the city argued, value attributable to rehabilitation.