Richland County Assessor v. Hull
Docket: Appellate Case No. 2013-001683; No. 2014-MO-018
Court: Supreme Court of South Carolina; June 18, 2014; South Carolina; State Supreme Court
The appellant contests an administrative law court's (ALC) valuation of their land for property tax purposes, asserting it was incorrectly assessed. The court affirms the ALC's decision, citing several legal standards and precedents. Key points include: 1. **Valuation Standards**: The property must be assessed at its true market value, determined by what it would sell for under standard market conditions, where both buyer and seller are informed and not under pressure (S.C.Code Ann. 12-37-930, Centex Int’l v. S.C. Dep’t of Revenue). 2. **Evidence Review**: The court cannot replace the ALC's factual determinations unless there is a lack of substantial evidence or a legal error. The ALC operates de novo, allowing it to evaluate the case as if it were new rather than merely reviewing prior decisions. 3. **Burden of Proof**: The property assessor bears the burden to demonstrate the correctness of their valuation. The taxpayer only needs to show that the assessor's valuation is incorrect, which can be done through evidence of the property's actual value or other means that rebut the presumption of correctness. 4. **Constitutionality**: The General Assembly holds the authority to define property classes for taxation and establish valuation methodologies, as outlined in the South Carolina Constitution. The court confirms that the legislative framework supports uniform and equal property assessment across defined classifications. The ruling is affirmed unanimously by the justices involved.