On October 9th, the Wyoming Supreme Court issued an opinion that sided with the Uinta County Assessor against the State of Wyoming.
The case was in regard to land the state owns but leases to a private company in Evanston for a truck stop. County Assessors have long argued that property owned by the government but not used for a governmental purpose should be taxable. The Uinta County Assessor taxed the property and the State applied for a tax exemption, which the Assessor denied.
The State appealed the issue to the County Commissioners, sitting as the County Board of Equalization, who found for the State. The Assessor appealed their decision to the State Board of Equalization, who reversed the County’s decision and sided with the Assessor. The State appealed to the District Court, who sided with the Assessor, and finally to the Supreme Court.
In pleadings to the Court, the State argued that, since the primary purpose of the land leased to the truck stop was to support the state hospital, the lease was for a “governmental purpose.” The State also argued that finding the State liable for taxes on the property would have broad implications for other lands managed by the State Board of Land Commissioners. The State wrote, “The Board leases millions of acres of state land to private entities who conduct commercial businesses on the land. For example, grazing livestock by a private lessee is not a governmental purpose … the vast majority of state lands are leased to private entities who conduct commercial business, not governmental purposes.”
The Court was not compelled by either argument, finding that the lease was not a governmental purpose and that the Court is not required to consider the implications of their decisions, only whether their decision is Constitutional. The Court noted the legislature had opportunity to exempt the property from taxation through statute but had declined.
The decision may indeed have a significant impact on property tax rolls and taxes, if Assessors statewide begin adding land owned by the State but leased to others for grazing, minerals, or other purposes.