AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• El Castillo Retirement Residences (El Castillo), a continuing care retirement community in Santa Fe, sought a charitable property tax exemption, which was denied by the Santa Fe County Assessor (the Assessor). El Castillo appealed this decision, claiming entitlement to the exemption under both statutory and constitutional provisions. The Santa Fe County Valuation Protests Board (the Protests Board) determined El Castillo was ineligible for the exemption under the statutory provision and declined to decide on the constitutional claim, citing lack of jurisdiction. El Castillo then appealed to the district court, which found in favor of El Castillo on both grounds (paras 2-4).

Procedural History

• Protests Board: Denied El Castillo's claim for a charitable property tax exemption under statutory grounds and declined to decide on the constitutional claim due to lack of jurisdiction.
• District Court of Santa Fe County: Reversed the Protests Board's decision, granting El Castillo a charitable property tax exemption under both statutory and constitutional grounds (para 4).

Parties' Submissions

• El Castillo: Argued that it qualifies for a charitable property tax exemption under both the New Mexico Property Tax Code and the New Mexico Constitution, citing its role as a continuing care retirement community that provides various levels of care and services to its residents (paras 2-4).
• Assessor: Contested El Castillo's eligibility for the exemption, arguing that El Castillo did not meet the necessary criteria under the statutory or constitutional provisions for a charitable property tax exemption (paras 1, 5).

Legal Issues

• Whether El Castillo is entitled to a charitable property tax exemption under the New Mexico Property Tax Code, NMSA 1978, Section 7-36-7(B)(1)(d) (2008) (para 1).
• Whether El Castillo meets the constitutional requirements for a charitable property tax exemption under Article VIII, Section 3 of the New Mexico Constitution (para 1).

Disposition

• The court did not have jurisdiction to review El Castillo's entitlement to a charitable property tax exemption under the statutory provision due to the Assessor's failure to perfect his appeal regarding the statutory exemption (para 12).
• The court reversed the district court's decision on the constitutional issue, concluding that El Castillo does not meet the constitutional requirements for a charitable property tax exemption (para 45).

Reasons

• The court found that the Assessor failed to file a petition for writ of certiorari to perfect his appeal on the statutory issue, rendering the court without jurisdiction to review that aspect of the case (paras 6-12). On the constitutional issue, the court determined that El Castillo's operations did not primarily and substantially serve a charitable purpose that benefits the public in a manner recognized under the New Mexico Constitution. The court noted that El Castillo's model is designed to be self-sustaining, funded by resident fees, and caters to individuals who meet certain financial criteria, which does not confer a substantial public benefit of real worth and importance to an indefinite class of persons who are part of the public (paras 13-44).