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Court weighs whether tax‑appeal petition is moot after assessor left office and whether petitioners must exhaust administrative remedies
Summary
In Jamie Holdings LLC v. Utah State Tax Commission, the court examined whether claims aimed at a former Wasatch County assessor are moot after his departure, and whether petitioners may seek Rule 65B relief without first exhausting statutory administrative remedies.
The Utah Court of Appeals heard oral argument in Jamie Holdings LLC’s appeal of a denial in part of a motion to dismiss in a petition under Rule 65B, a remedy in the nature of mandamus. Andrew Demick, representing the Utah State Tax Commission, urged the court to find the claim against the commission moot because the assessor at issue, Todd Griffin, is no longer in office, and to require petitioners to exhaust administrative remedies before pursuing extraordinary relief in court.
Demick told the panel the taxpayers’ requested relief — including orders to seek Griffin’s removal and other corrective actions — was tied to Griffin’s conduct and, with a successor in office, no longer advances the petitioners’ interests. “The claim against the commission is moot,” Demick said, arguing that dismissal without prejudice and remand to let the trial court consider substitution and possible amendment would be appropriate.
Petitioners’ counsel, Robert Mansfield, countered that the petition alleges a systemic failure in Wasatch County appraisal practice that administrative channels cannot remedy and therefore falls within the Rule 65B framework. He argued that thousands of parcels were not annually assessed and that the effect has been countywide tax‑rate distortions the administrative appeals process cannot cure.
The panel focused on two practical questions: (1) whether an elected‑official change moots claims tied to the former official and (2) whether petitioners may proceed in the appellate posture without first using the Property Tax Act’s administrative pathways. Judges discussed Rule 25D substitution of a successor official and suggested that an off‑ramp could be dismissal of claims as moot against the former assessor while remanding so the trial court can decide substitution and whether petitioners should be given leave to amend.
What happens next: The court will take the arguments under advisement and later issue a written disposition clarifying whether the claims as pled are moot and whether further proceedings in the trial court (substitution, leave to amend, or dismissal) are warranted.
