The Missouri Supreme Court made permanent its preliminary writ of mandamus against Judge David Chamberlain, ordering him to dismiss a putative class action lawsuit challenging Jackson County property tax assessments. The December 19, 2023 ruling represents a significant victory for Jackson County and reinforces the requirement that taxpayers must exhaust all administrative remedies before pursuing judicial relief in property tax disputes.
The case, *State ex rel. Jackson County, Missouri v. The Honorable David Chamberlain*, arose from a June 20, 2023 lawsuit filed by Jackson County property owners challenging increases to their assessed property values. The taxpayers alleged that the county violated state law by failing to provide proper notice of assessment increases by June 15, as required by sections 137.180 and 137.355 of Missouri statutes, and by failing to conduct physical inspections of properties that increased in value by more than 15 percent.
According to the taxpayers' allegations, these procedural failures rendered the increases in assessed value void. The property owners sought to bring their challenge as a class action, potentially affecting numerous Jackson County residents who experienced similar assessment increases during the 2023 valuation cycle.
Jackson County, along with several county officials including the assessor, collector, board of equalization chair, vice chair, and a board member, filed a motion to dismiss the lawsuit. The county argued that the taxpayers had failed to exhaust all available administrative remedies before filing suit in circuit court. This argument centers on Missouri's established legal framework requiring property owners to follow specific procedural steps when challenging tax assessments.
In Missouri's property tax system, real property is assessed on a two-year cycle, with county assessors placing values on properties in odd-numbered years. When property owners disagree with their assessments, they must typically pursue administrative remedies through the county board of equalization and state tax commission before seeking judicial relief.
In October 2023, the circuit court overruled Jackson County's motion to dismiss, allowing the taxpayers' lawsuit to proceed. This decision prompted Jackson County to seek extraordinary relief from higher courts through a mandamus proceeding.
Mandamus is an extraordinary legal remedy that compels a lower court or government official to perform a specific duty required by law. In this case, Jackson County argued that the circuit court judge was legally required to dismiss the lawsuit because the taxpayers had not followed proper administrative procedures.
The Missouri Supreme Court agreed with Jackson County's position. The state's highest court determined that because the taxpayers failed to exhaust all available administrative remedies before filing suit, the underlying action must be dismissed. The court made permanent its preliminary writ of mandamus, effectively ordering Judge Chamberlain to vacate his earlier ruling and grant the county's motion to dismiss.
This ruling reinforces Missouri's well-established doctrine requiring exhaustion of administrative remedies in property tax disputes. The doctrine serves several important purposes: it allows administrative agencies with specialized expertise to review disputes first, promotes efficiency in the legal system by resolving issues without court involvement when possible, and ensures that courts are not burdened with cases that could be resolved through existing administrative processes.
For Jackson County property owners, this decision means they must pursue their assessment challenges through the proper administrative channels before seeking court relief. This typically involves filing appeals with the county board of equalization within specified time limits and, if necessary, appealing adverse decisions to the state tax commission.
The ruling has broader implications for property tax disputes across Missouri. It clarifies that taxpayers cannot bypass administrative procedures even when alleging systemic violations by county officials. This reinforces the structured approach Missouri law requires for challenging property assessments and may influence how similar disputes are handled in other counties.
For Jackson County officials, the decision validates their position that the proper legal procedures must be followed in tax assessment challenges. The ruling allows county officials to continue their assessment and collection processes without the uncertainty created by pending litigation that bypassed administrative remedies.
The case also highlights the importance of procedural compliance in Missouri's property tax system. While taxpayers retain the right to challenge assessments they believe are unlawful, they must follow established procedures that provide orderly resolution of disputes.
Looking forward, affected Jackson County property owners who wish to challenge their 2023 assessments must now pursue administrative remedies if they have not already done so. The specific time limits and procedures for such challenges are governed by Missouri statutes and county regulations. Property owners who have missed administrative deadlines may need to wait for the next assessment cycle to raise their challenges, depending on the specific circumstances and applicable laws.