MBN 500-1200 Buildings, LLC v. Alabama Department of Revenue (Appeal from Shelby Circuit Court: CV-18-900604).
Ala.1/17/2025
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Full Opinion
Rel: January 17, 2025
Notice: This opinion is subject to formal revision before publication in the advance sheets of Southern
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SUPREME COURT OF ALABAMA
OCTOBER TERM, 2024-2025
_________________________
SC-2024-0013
_________________________
MBN 500-1200 Buildings, LLC
v.
Alabama Department of Revenue
Appeal from Shelby Circuit Court
(CV-18-900604)
_________________________
SC-2024-0014
_________________________
SC-2024-0013 and SC-2024-0014
MBN Building 300, LLC
v.
Alabama Department of Revenue
Appeal from Shelby Circuit Court
(CV-18-900605)
COOK, Justice.
SC-2024-0013 -- AFFIRMED. NO OPINION.
SC-2024-0014 -- AFFIRMED. NO OPINION.
See Rule 53(a)(1) and (a)(2)(F), Ala. R. App. P.
Shaw, Wise, Sellers, Mendheim, Stewart, and Mitchell, JJ., concur.
Cook, J., concurs specially, with opinion.
Parker, C.J., dissents.
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COOK, Justice (concurring specially).
I concur fully with this Court's decision to affirm the judgments. I
write specially, however, because this case illustrates how a rule of
evidence can help generate a result that some might consider mistaken
and to explain why the applicable rule of evidence in these cases might
need to be reconsidered.
Background
To summarize a complicated record, MBN Building 300, LLC, and
MBN 500-1200 Buildings, LLC (collectively referred to as "MBN"), each
own commercial office buildings in Hoover. After the Shelby County Tax
Commissioner's Office assessed the fair market values of those buildings
-- Building 300, Building 500, and Building 1200 -- for the 2018 tax year,
MBN challenged those assessments before the Shelby County Board of
Equalization and Adjustments ("the BOE"). The BOE affirmed the
Commissioner's assessments.
MBN then appealed those assessments1 to the Shelby Circuit
1MBN initially appealed only the BOE's assessed values for the
buildings for the 2018 tax year, but the assessed values for the 2019,
2020, 2021, 2022, and 2023 tax years were subsequently added to the
appeals below.
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Court2 and requested a jury trial to determine the fair market values of
those buildings. After the Alabama Department of Revenue ("ADOR")
filed a notice of appearance and became the named "appellee" in the
appeals below,3 the cases were tried together.
I. The Trial
The jury had a tough assignment. Establishing the fair market
value for a commercial office building is not simple or exact. There are
far fewer comparable sales as would exist for ordinary home sales.
Establishing a value is especially difficult when, as here, one of the
buildings at issue -- Building 300 -- produced no income and had no
tenants during any of the pertinent tax years (and Building 500 had no
tenants for a significant number of those years). For the purposes of this
writing, I note that MBN and ADOR presented the following relevant
evidence and arguments to the jury concerning the valuations for the
2See §§ 40-3-24 and 40-3-25, Ala. Code 1975.
3The BOE initially entered a limited appearance in the appeals for
the purpose of submitting its "Certified Statement of Assessment or
Valuation" for the buildings pursuant to § 40-3-25, Ala. Code 1975. ADOR
subsequently filed a notice of appearance, see § 40-3-26(b), Ala. Code
1975, and became the named "appellee" in the appeals below.
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pertinent tax years.
A. ADOR's Expert-Opinion Testimony
At trial, ADOR explained the methods used by the Shelby County
Tax Commissioner and the BOE to arrive at the assessed values in these
cases and argued that the way they assessed the values for the buildings
was more reliable than the expert testimony of the appraisers offered by
MBN. In support of this position, ADOR had Lisa Cooley, the chief
appraiser of the Shelby County Tax Commissioner's Office, testify as an
expert witness.
Cooley testified that the original assessed values set by the
Commissioner were determined by using the "cost approach." To arrive
at those values, Cooley explained that the tax assessor inventoried all
improvements to the buildings, estimated the current cost to construct
similar buildings, and discounted for depreciation. Cooley also testified
that the cost approach was generally accepted and was a good way to
value the buildings.
Additionally, Cooley testified that, in completing the assessment
process, the BOE engages in "mass appraisal" and "equalization." As part
of the BOE's "mass-appraisal" process, Cooley explained, the BOE
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"equalizes" assessed tax values so that similar properties in a similar
area are "treated equally." As part of that process, she stated, the BOE
considers the market in areas with "the same attributes, the same traffic
counts, the same school district, [and] the same city limit." Properties
that are of the same "building types" within each of those areas are
considered together. Cooley testified that only rarely can a building
deviate from its equalized value. 4
Cooley further explained that, as a part of this mass-appraisal
process, the Shelby County Tax Commissioner's Office reviews actual
property sales of only "validated properties" in similar areas and
calculates per-square-foot values, which are then compared to all
appraised tax values in the area. According to Cooley, the Shelby County
Tax Commissioner's Office must forward its validated properties to
ADOR. The assessed values, she explained, are required to be between
98% and 102% of those validated sale prices.
4When asked why a property would be valued differently from the
properties used to equalize it, Cooley explained that there would be a
deviation if a specific property has "structural damages," like if
"tornadoes come through, and maybe it hit one building and it didn't [hit]
other[s]." Even if a deviation from the equalized value is permitted due
to structural damage, however, Cooley explained that the deviation is
removed once the damage is repaired.
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Finally, Cooley claimed that mass appraisal is not subjective and is
designed to eliminate "all guesswork" and "all uncertainty." Cooley
contrasted the BOE's mass-appraisal approach with MBN's approach,
which she described as being "very opinionated."
Notably, Cooley also testified that the Shelby County Tax
Commissioner's Office would consider any income information provided
by the property owner and would appraise the property using an "income
approach," if requested. However, no such documentation was provided
by MBN before it initiated the appeals below regarding Building 300 and
Building 500. One possible reason for MBN's not doing so could have been
because Building 300 had no tenants during any of the pertinent tax
years and because Building 500 had no tenants for a significant portion
of those years. As a result, there was no "income" that could have been
submitted for consideration.
B. MBN's Evidence
During its case-in-chief at trial, MBN argued that the methods
employed by the Shelby County Tax Commissioner's Office and the BOE
were unreliable. MBN argued that Cooley's testimony was inadmissible
because it was irrelevant (at least to the extent that it concerned BOE's
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internal processes) and because she had testified about buildings and
methods with which she had no personal familiarity. MBN also argued
that its methods of valuation were superior. In support of its assertions,
MBN presented expert testimony from various appraisers and
commercial real-estate brokers who had experience valuing properties
like the buildings at issue here.
For instance, during their testimony, MBN's experts were asked
about the BOE's use of sales for mass appraisal. Relying on that
testimony, MBN argued that the BOE's method was fundamentally
flawed because the "validated properties" used by the BOE were not
comparable to MBN's buildings. Specifically, MBN argued that the BOE
intentionally ignored sales of properties involving trusts and otherwise
failed to consider other properties that were larger commercial buildings.
MBN also alleged that the best evidence of a property's value is
what a willing buyer will pay a willing seller. See Morgan Cnty. Bd. of
Equalization v. Indorama Ventures Xylenes & PTA, LLC, [Ms. SC-2023-
0183, Mar. 22, 2024] ____ So. 3d ____, ____ (Ala. 2024) (recognizing that
"fair market value" of a piece of property is " ' " ' the sum arrived at by fair
negotiation between an owner willing to sell and a purchaser willing to
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buy, neither being under pressure to do so' " ' " (quoting Mt. Carmel
Estates, Inc. v. Regions Bank, 853 So. 2d 160, 166 (Ala. 2002)) (emphasis
added)); § 40-1-1(16), Ala. Code 1975 (defining the term "value" as the
"fair and reasonable market value of property, estimated at the price
which the property would bring at a fair voluntary sale").
For instance, although MBN disputed the valuations for three of its
buildings, it especially disagreed with the values assessed for Building
300. The record reflects that, in 2017, MBN purchased Building 300 for
$2,500,000. During the pertinent tax years, MBN was never able to
secure a tenant for that building and, thus, that building sat completely
empty for six years.
In July 2023, however, MBN sold Building 300 for $5,000,000.
According to MBN, the prices at which it purchased and then later sold
Building 300 were the best evidence of that building's fair market value
because those prices reflected what a willing buyer would pay a willing
seller for that property. Thus, MBN argued, those values should have
been used in calculating the ad valorem taxes against it. Nevertheless,
the values set by the Commissioner and the BOE for the ad valorem taxes
for that building ranged from $9,650,590 for the 2018 tax year to
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$12,434,060 for the 2023 tax year.
C. The Jury's Verdicts
Following a contentious four-day trial, the jury returned verdicts
setting the fair market values for Building 300, Building 500, and
Building 1200 for each of the pertinent tax years. Although those values
were less than the original valuations affirmed by the BOE, they were
far closer to the BOE's valuations than the values advocated by MBN. In
particular, for Building 300, the jury found a value of approximately
$10,000,000 (varying over time) -- despite the actual sale of that building
for $5,000,000.
II. The Present Consolidated Appeals
After MBN's motions for a new trial or, in the alternative, to alter
or amend the judgments entered on the jury's verdicts, were denied, MBN
filed the present consolidated appeals with this Court, pursuant to § 40-
3-25(d), Ala. Code 1975.5 In these appeals, MBN has challenged only the
judgments concerning Building 300 and Building 500.
5That Code section states, in relevant part: "From the judgment of
the circuit court, either the state or the taxpayer may appeal directly to
the Supreme Court of Alabama within 42 days of the entry of the
judgment." (Emphasis added.)
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Discussion
One of the key arguments raised by MBN both during trial and in
the present consolidated appeals is that the expert testimony presented
by ADOR, explaining the methods used to calculate the values
underlying the assessed ad valorem taxes, is unreliable. This special
writing concerns the evidentiary standard used to admit that expert
testimony, which, as explained below, is lower because the testimony at
issue was not "scientific" in nature.
I. Alabama's Rule Governing Expert Testimony -- Rule 702, Ala. R.
Evid.
In Alabama, expert testimony is generally governed by Rule 702(a),
Ala. R. Evid., which provides a modest standard for parties to meet. That
rule states, in relevant part:
"(a) If scientific, technical, or other specialized
knowledge will assist the trier of fact to understand the
evidence or to determine a fact in issue, a witness qualified as
an expert by knowledge, skill, experience, training, or
education may testify thereto in the form of an opinion or
otherwise."
However, expert testimony that is based on a "scientific theory,
principle, methodology, or procedure" must also meet the requirements
of Rule 702(b), Ala. R. Evid., which states:
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"(b) In addition to the requirements in section (a), expert
testimony based on a scientific theory, principle, methodology,
or procedure is admissible only if:
"(1) The testimony is based on sufficient facts
or data;
"(2) The testimony is the product of reliable
principles and methods; and
"(3) The witness has applied the principles
and methods reliably to the facts of the case."
Before such testimony can be presented at trial, our courts require "the
proponent of scientific evidence to show that such evidence is 'reliable' by
establishing the scientific validity (i.e. reliability) of the scientific theory,
principle, methodology, or procedure that the expert relied upon in
forming his or her conclusions." 2 Charles W. Gamble et al., McElroy's
Alabama Evidence §127.03(1) (7th ed. 2020) (footnote omitted).
From the early 1950s until 2012, courts in Alabama used the
"general acceptance" test announced in Frye v. United States, 54 App.
D.C. 46, 293 F. 1013 (1923), to evaluate the evidentiary reliability of
scientific evidence offered during trial. See id. 6 Now, when it comes to the
6Under that test, "a person who offers an opinion as a scientific
expert must prove that he relied on scientific principles, methods, or
procedures that have gained general acceptance in the field in which the
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admissibility of expert testimony based on scientific opinions, courts in
Alabama apply Rule 702(b), which is based on a modified version of the
test that was announced in Daubert v. Merrell Dow Pharmaceuticals,
Inc., 509 U.S. 579 (1993), and is used in federal courts. 7
Unlike in Alabama, at the federal level, all expert testimony --
whether scientific or nonscientific -- is subject to the more exacting
Daubert standard. See, e.g., Kumho Tire Co. v. Carmichael, 526 U.S.
137, 141 (1999) (recognizing that the Daubert analysis applies to all
expert is testifying." Slay v. Keller Indus., Inc., 823 So. 2d 623, 626 (Ala.
2001).
7I note briefly that the admissibility criteria in Daubert was
formally adopted through an amendment to Rule 702, Ala. R. Evid., that
became effective on January 1, 2012. See Rule 702(b), Ala. R. Evid. See
also Advisory Committee Notes to Amendment to Rule 702, Ala. R. Evid.,
Effective January 1, 2012 (explaining that "[t]he language in subsections
(b)(1), (b)(2), and (b)(3) is identical to language added to Rule 702 of the
Federal Rules of Evidence in response to the United States Supreme
Court's decision in Daubert …. The amendment adopts the approach
taken in Daubert for determining the admissibility of scientific
evidence."). That amendment was adopted to make Rule 702 consistent
with a legislative amendment to Alabama's statute on expert witnesses -
- § 12-21-160, Ala. Code 1975 -- which also became effective on January
1, 2012.
In the present cases, MBN has not argued whether the Frye test
may still have some limited application for expert testimony that is not
covered by Rule 702(b), and I take no position on this issue.
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proposed expert testimony, including nonscientific "technical analysis"
and other "specialized knowledge"). This allows the judge to act as the
"gatekeeper" for what an expert witness will or will not be allowed to
testify to. See Daubert, 509 U.S. at 597.
Practitioners in our state have recognized the difficulty in
determining whether certain expert testimony is "based on a scientific
theory, principle, methodology, or procedure," stating:
"Rule 702(b) applies to expert testimony only if it is
'based on a scientific theory, principle, methodology or
procedure.' Thus, Rule 702(b) does not apply to expert
testimony based on 'technical' or 'other specialized
knowledge.' Deciding whether a particular expert's testimony
is or is not scientific is a difficult issue for Alabama judges and
lawyers. 'Scientific' is not defined in Rule 702, and, after
decades of applying the Frye [v. United States, 54 App. D.C.
46, 293 F. 1013 (1923),] standard (which applied only to novel
scientific testimony), it is 'apparent that Alabama courts have
not attempted to narrowly define the phrase "scientific test or
experiment," ' but rather 'have been content to determine on a
case-by-case basis whether proffered testimony implicates a
scientific test or experiment.'30
"_______________________
"30See Robert J. Goodwin, Fifty Years of Frye in
Alabama: The Continuing Debate over Adopting the Test
Established in Daubert v. Merrill Dow Pharmaceuticals, Inc.,
35 Cumb. L. Rev. 231, 245-46 (2005)."
Terrence W. McCarthy & Brooke G. Malcom, Alabama's Daubert
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Amendment: An Overview of the Current State of the Law and Resources
for the Practitioner, 79 Ala. Law 254, 260 (July 2018).
That said, our Court, quoting from the Eleventh Circuit Court of
Appeals' decision in Carmichael v. Samyang Tire, Inc., 131 F.3d 1433,
1435-36 (11th Cir. 1997), has previously explained that the following is
helpful in determining what is and is not scientific evidence:
" 'What, then, is the difference between scientific and
non-scientific expert testimony? In short, a scientific expert is
an expert who relies on the application of scientific principles,
rather than on skill- or experience-based observation, for the
basis of his opinion. See Daubert [v. Merrell Dow
Pharmaceuticals, Inc.], 509 U.S. [579,] 590, 113 S. Ct. [2786,]
2795, 125 L.Ed.2d 469 [(1993)]. As the Sixth Circuit explained
in Berry v. City of Detroit:
" ' "The distinction between scientific and
non-scientific expert testimony is a critical one. By
way of illustration, if one wanted to explain to a
jury how a bumblebee is able to fly, an
aeronautical engineer might be a helpful witness.
Since flight principles have some universality, the
expert could apply general principles to the case of
the bumblebee. Conceivably, even if he had never
seen a bumblebee, he still would be qualified to
testify, as long as he was familiar with its
component parts.
" ' "On the other hand, if one wanted to prove
that bumblebees always take off into the wind, a
beekeeper with no scientific training at all would
be an acceptable witness if a proper foundation
were laid for his conclusions. The foundation
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would not relate to his formal training, but to his
firsthand observations. In other words, the
beekeeper does not know any more about flight
principles than the jurors, but he has seen a lot
more bumblebees than they have."
" '25 F.3d 1342, 1349-50 (6th Cir.1994); see also Sorenson v.
Robert B. Miller & Assoc., Inc., Nos. 95-5085, 95-5086, [Sept.
10, 1996 (6th Cir. 1996) (not published in Federal Reporter)]
(applying Berry). Thus, the question in this case is whether
[the expert's] testimony is based on his application of scientific
principles or theories (which we should submit to a Daubert
analysis) or on his utilization of personal experience and skill
with failed tires (which we would usually expect a district
court to allow a jury to evaluate). In other words, is the
testimony at issue in this case more like that of a beekeeper
applying his experience with bees or that of an aeronautical
engineer applying his more generalized knowledge of the
scientific principles of flight?' "
Ex parte George, 370 So. 3d 591, 603 (Ala. 2021) (plurality opinion).
II. Applying Rule 702, Ala. R. Evid., in the Present Cases
In the present cases, Cooley's testimony addressing the methods
used by the Shelby County Tax Commissioner's Office to calculate and
assess the values of commercial properties for ad valorem taxes is not
based on her application of scientific principles or theories but is, instead,
based on her training and experience as the chief appraiser.8 Thus, under
8Although it is perhaps possible to argue that the "mass-appraisal"
process is a scientific "methodology" or "procedure," the process of
deciding what properties should be included in the process -- that is,
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current Alabama evidentiary practice, the Daubert standard would not
have been applied to her testimony in this case. Instead, it appears to me
to have been properly admitted under the lower standard of Rule 702(a). 9
Even so, there are good reasons to think that such testimony should
be subjected to the Daubert standard. Why? Because it is possible that
the methods used for calculating the assessed values for ad valorem taxes
in this state -- as described by Cooley -- could result in skewed
assessments, particularly where, as here, there is no rental information
"validated" -- does not seem scientific at all. Regardless, I need not decide
such a question because MBN has not argued that Rule 702(b) should
have been applied here.
9It is possible that Cooley's testimony might also have been
admitted as lay opinion testimony, but it would likely have had far less
impact on the jury as lay opinion testimony. Moreover, after reviewing
the transcript of the trial below, I do not believe that this testimony was
presented or admitted as lay opinion testimony at trial. ADOR clearly
wished the jury to view Cooley as someone with expertise. Further, any
such lay opinion testimony would still need to pass other admissibility
requirements, and I express no opinion on whether it would have met
such requirements. See Rule 701, Ala. R. Evid. (providing that lay
opinion testimony is allowed if (among other things), it is "rationally
based on the perception of the witness"). See also Presley v. B.I.C.
Constr., Inc., 64 So. 3d 610, 620 (Ala. Civ. App. 2009) (quoting State v.
Steele, 374 So. 2d 325, 329 (Ala. 1979)) (explaining that " '[i]t is well-
settled that any person, including a layman, is competent to testify to his
opinion concerning the value of land if he has had an opportunity for
forming a correct opinion and testifies in substance that he has done so' ").
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available for the buildings at issue.
Testimony offered by ADOR during trial indicated that, every year,
the Shelby County Tax Commissioner's Office -- and, presumably, all
county tax commissioner's offices in Alabama -- compile a sales-ratio
study for the current tax year that includes all the appraised values and
all the actual sales of "validated properties" in similar areas. After the
per-square-foot values are calculated using those sales, they are then
compared to appraised tax values in the area. That report is then
submitted to ADOR, which does its own studies to ensure that a
particular county is being "fair and equitable" in its assessments of real
property in the area.
However, according to Cooley, the Shelby County Tax
Commissioner's Office intentionally excludes all properties owned or
purchased by a "trust" from its study, and, as a result, such properties
can never be "validated properties." She explained that, if she does not
exclude them, ADOR will ask her to remove them. In other words,
excluding those types of properties from the study for assessment of the
values of commercial properties may be standard practice across
Alabama.
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In these cases, MBN noted that there was at least one property --
the Inverness Center -- that was owned by a trust and was excluded from
the Shelby County Tax Commissioner's calculations. MBN alleged that
the Inverness Center was very similar to the buildings at issue here and,
thus, should have been used as a comparable sale in determining the
average square-foot price for the buildings at issue. Again, determining
the value of commercial office buildings is particularly difficult because
there are few comparable sales.
Even more troubling to me is that one type of commercial property
that is intentionally omitted from the BOE's methodology is commercial
property owned by a real-estate investment trust, known colloquially as
a "REIT." A REIT is "[a] company that invests in and manages a portfolio
of real estate, with the majority of the trust's income distributed to its
shareholders." Black's Law Dictionary 1516 (11th ed. 2019). Many REITs
are publicly traded and provide important benefits to investors and
society. As a result, REITs have the ability to raise large amounts of
capital to finance larger projects. In fact, much of the commercial real
estate in the United States is owned by REITs.
It is self-evident that it takes more money to purchase a larger
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commercial property and, thus, that REITs will, as a general matter, own
larger commercial properties. Therefore, it is the larger commercial office
buildings that are more often left out of the "validated properties" by
ADOR and the BOE. Why is this important? Because even Cooley --
ADOR's own witness -- admits that, in general, the larger the building
the lower the price per square foot.
By intentionally excluding REIT-owned commercial properties, it
seems possible that the methods used for assessing the values of
commercial properties for ad valorem taxes in Alabama is skewing the
square-footage calculation in the mass-appraisal process toward a higher
value. Had Cooley's testimony been subject to the Daubert standard, it
might have been excluded because, among other reasons, it was neither
"based on sufficient facts or data" nor, arguably, "the product of reliable
principles and methods" because it omitted such REIT-owned properties.
Rule 702(b).
I say "might" and "possible" because there was no Daubert hearing
held by the circuit court to determine if excluding REIT-owned properties
did in fact skew the assessments at issue in these cases. Thus, I do not
(and need not) conclude that the valuations in these cases -- or that any
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other valuations by the Shelby County Tax Commissioner that exclude
consideration of REIT-owned property -- are inaccurate. Likewise, I
cannot say whether the admission of such testimony directly led to the
jury's determining a taxable value of Building 300 that was basically
double its actual sales price in 2023. All I can say is that it concerns me.
Despite my concerns, however, the job of Alabama's courts,
including this Court, is to apply the existing law. We are thus bound by
Alabama's current evidentiary standards. Here, there seems to be little
doubt that Cooley's testimony explaining the valuations at issue in these
cases was properly admitted at trial under Alabama's existing
evidentiary standards in Rule 702(a) and that, therefore, the jury could
appropriately have relied on her testimony in reaching its verdicts here.
In my view, our citizens are entitled to the most accurate results by
county tax-assessing officials and in the Alabama courts. Importantly,
the Alabama economy works best when investors from Alabama and from
across the nation are confident that they will receive predictable and
accurate results in our courts. I thus make the above observations in the
hope that the Legislature -- and, perhaps, the Standing Committee on
the Alabama Rules of Evidence -- will consider whether Alabama should
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adopt the Daubert reliability standard for all expert testimony regardless
of whether it is scientific in nature. I also make the above observations
in the hope that ADOR considers the question of whether it should
include REIT-owned properties and certain trust-owned properties in its
tax-assessment calculations.
22
Case Information
- Court
- Ala.
- Decision Date
- January 17, 2025
- Status
- Precedential