German Evangelical Lutheran Church v. City of Charleston

Justice BURNETT

dissenting:

I respectfully dissent. In my opinion, the General Assembly intended to exclude owners of property exempt from ad valorem taxation from assessment under the Municipal Improvement Act. Accordingly, I would reverse the trial judge’s order granting summary judgment in favor of the City.

The cardinal rule of statutory construction is that the Court ascertain and effectuate the actual intent of the legislature. Burns v. State Farm Mut. Auto. Ins. Co., 297 S.C. 520, 377 S.E.2d 569 (1989). A statute as a whole must receive a practical, reasonable, and fair interpretation consonant with the purpose, design, and policy of the lawmakers. Browning v. Hartvigsen, 307 S.C. 122, 414 S.E.2d 115 (1992).

As originally enacted, the predecessor to South Carolina Code Ann. § 5-37-40(B) (Supp. 2001) provided:

... If the governing body shall find ... and (v) that it would be fair and equitable to finance all or part of the cost *610of such improvements by an assessment upon the real property located within such district, the governing body may establish such area as an improvement district and implement and finance, in whole or in part, an improvement plan therein in accordance with the provisions of this act; provided, that the governing body shall, prior to the enactment of the ordinance creating the improvement district, obtain written consent for the creation of such improvement district from a majority in number of the owners of real property within the district and having an aggregate assessed value in excess of sixty-six percent of the assessed value of all real property within such improvement district.

Act No. 1207, § 4, 1974 Acts 2813(italic in original) (underline added).

Thereafter, the General Assembly amended the Municipal Improvement Act as follows:

If the governing body finds that: ... (v) it would be fair and equitable to finance all or part of the cost of the improvements by an assessment upon the real property within the district, the governing body may establish the area as an improvement district and implement and finance, in whole or part, an improvement plan in the district in accordance with the provisions of this chapter. However, the governing body, prior to the enactment of the ordinance creating the improvement district, shall obtain written consent for the creation of the improvement district from a majority in number of the owners of real property within the district that is not exempt from taxation under the Internal Revenue Code and having an aggregate assessed value in excess of sixty-six percent of the assessed value of all real property within the improvement district that is not exempt from taxation under the Internal Revenue Code.

Act No. 160, § 1,1987 S.C. Acts 1081 (underline added).

The following year, the legislature again amended the Municipal Improvement Act to permit, in relevant part, adoption of an improvement district through initiative. In part, the statute provided:

... The ordinance creating an improvement district may be adopted by a majority of council after a public hearing at which the plan is presented, including the proposed basis of *611the assessment, or upon written petition signed by a majority in number of the owners of real property within the district which is not exempt from ad valorem taxation as provided by law.

Act No. 505, § 2,1988 S.C. Acts 4550.

In 1999, this section was again amended. It appears today as follows:

... The ordinance creating an improvement district may be adopted by a majority of counsel after a public hearing at which the plan is presented, including the proposed basis ■ and amount of assessment, or upon written petition signed by a majority in number of the owners of real property within the district which is not exempt from ad valorem taxation as provided by law. However, owner-occupied residential property which is taxed under Section 12-43-220(c) must not be included within an improvement district unless the owner gives the governing body written permission to include the property within the improvement district.

Act No. 118, 1999 S.C. Acts 1238 (codified at S.C. Code Ann. § 5-37-40 (Supp. 2001)).

The legislative history of the Municipal Improvement Act indicates the General Assembly’s clear intent to allow a municipality to assess the improvement fee only upon those property owners who have property which is subject to ad valorem taxation. See Wade v. Berkeley County, 348 S.C. 224, 559 S.E.2d 586 (2002) (in interpreting a statute, the Court will not ignore its clear legislative history). Until 1988, the Municipal Improvement Act required a municipality to obtain the consent of a majority of owners who had taxable real property with an assessed value in excess of sixty-six percent before establishing an improvement district. In 1988, the General Assembly deleted the majority consent requirement, but added a petition method which permitted a majority of tax-paying property owners to petition the municipality for creation of an improvement district. In 1999, the legislature added the provision which required owners of owner-occupied residential property to consent to inclusion of their property in the improvement district.

As I read the history of the Municipal Improvement Act, the General Assembly intended only those property owners *612who are subject to ad valorem taxation to pay the assessments for the improvement district. To hold otherwise and require churches and other charitable institutions who receive no economic benefit from the improvement district would be absurd.

Contrary to the majority’s analysis, the owner-occupied provision does not evince the legislature’s intent to exclude only owner-occupied residencies from the assessment. Instead, the provision indicates the General Assembly’s intent to exclude only one type of property subject to ad valorem taxation — owner-occupied residences — from the improvement district assessment. All other owners of property subject to ad valorem taxation are subject to the assessment. Since Church is not subject to ad valorem taxation,1 City may not assess Church for the improvement district.

Finally, Section 5-37-20(3) which precludes the State House grounds from inclusion in any special improvement district does not evince the General Assembly’s intent as to which property owners must pay the assessments for improvement districts.

In my opinion, the trial judge erred in granting summary judgment in City’s favor. I would reverse.

. S.C. Const, art. X, § 3.