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CROUSE HEALTH SYSTEM, INC. v. CITY OF SYRACUSE
Citation: Not availableDocket: CA 14-01124
Court: Appellate Division of the Supreme Court of the State of New York; March 20, 2015; New York; State Appellate Court
Original Court Document: View Document
The Supreme Court of New York, Appellate Division, reversed a prior order and judgment that had granted Crouse Health System, Inc. a summary judgment in a tax assessment challenge. The challenge was based on the denial of full tax exemptions for three parcels used for a garage and office space; the Commissioner of Assessment granted a 75% exemption for the garage but denied the rest. The court found that the initial proceeding was improperly brought under CPLR article 78 rather than the appropriate certiorari proceeding under RPTL article 7. It recognized that while Crouse Health is organized for exempt purposes as a hospital, the critical issue was whether the property was used exclusively for those purposes. The court emphasized that the burden of proof lies with the taxpayer to demonstrate entitlement to tax exemption and that Crouse Health failed to show that the primary use of the properties met the statutory requirements, as there was evidence that some garage users engaged in nonexempt activities. Consequently, the petition was dismissed regarding the CPLR article 78 relief sought. The private practice of medicine by a hospital’s attending physicians is classified as a commercial enterprise, and as such, these physicians’ offices do not qualify for a tax exemption under RPTL 420-a. Consequently, parking spaces subleased to these offices do not further the hospital's purposes sufficiently to warrant a tax exemption. The petitioner acknowledged that 6.3 to 8.2% of the garage's annual revenue comes from patrons attending nearby sporting and entertainment events, which is not an exempt use. Additionally, while the petitioner indicated that 10% of one office building and 20% of another were used for nonexempt purposes, it did not conclusively demonstrate the specific use of the remaining office space. As a result, the petitioner failed to establish its entitlement to summary judgment. The court erred in accepting the respondents' admission of all facts in the petitioner’s "Statement of Undisputed Material Facts" because the statement mirrored an employee's affidavit, which the respondents disputed. The petitioner did not provide adequate admissible evidence to support this statement, and while the court has the discretion to deem facts admitted, it was not obligated to do so. The evidence presented did not resolve all factual disputes, and the court was not required to grant summary judgment based solely on procedural adherence to Rule 19-a.