99 A.D.2d 600 (1984)
The existence of a conservation easement does not automatically diminish the assessed value of the property if the easement does not impact the highest and best use of the land.
Summary
Adirondack Mountain Reserve (AMR) challenged real property tax assessments after conveying a large portion of its land to the state and granting a conservation easement on the retained land. AMR argued that the easement reduced the value of the remaining property. The trial court found, and the Appellate Division affirmed, that the easement did not diminish the highest and best use of the retained property, and there were sufficient factual findings supporting the property’s valuation. The New York Court of Appeals affirmed, holding that the factual findings were beyond their scope of review.
Facts
Adirondack Mountain Reserve (AMR) owned approximately 16,000 acres of real property. In 1978, AMR conveyed over 9,000 acres to the State of New York. AMR granted the State a conservation easement burdening its retained lands. AMR initiated proceedings to review the real property tax assessments on its retained property, arguing the assessments should be reduced due to the conveyance and easement.
Procedural History
AMR instituted proceedings in the trial court pursuant to Article 7 of the Real Property Tax Law to challenge the assessments. The trial court upheld the assessments. The Appellate Division unanimously affirmed the trial court’s decision. AMR appealed to the New York Court of Appeals.
Issue(s)
Whether the conservation easement granted by Adirondack Mountain Reserve diminished the highest and best use, and therefore the assessed value, of its retained property for tax assessment purposes.
Holding
No, because there was support in the record for the trial court’s finding, affirmed by the Appellate Division, that the easement did not diminish the highest and best use of the petitioner’s retained property, and there were affirmed factual findings as to the value of the property on the taxable status date.
Court’s Reasoning
The Court of Appeals affirmed the Appellate Division’s order, emphasizing that the lower courts made factual findings regarding the impact of the conservation easement and the value of the property. The court stated, “There is support in the record for the trial court’s finding, affirmed by the Appellate Division, that the easement did not diminish the highest and best use of petitioner’s retained property. There are also affirmed factual findings as to the value of the property on the taxable status date. The matter is therefore beyond the scope of our review.” The Court of Appeals generally does not disturb affirmed factual findings if they are supported by the record. The court’s decision highlights the importance of establishing a clear factual record to demonstrate that a conservation easement has negatively impacted the highest and best use of the property in order to achieve a reduction in assessed value for property tax purposes. The case implies that merely granting a conservation easement is not sufficient; the property owner must show how the easement restricts potential uses of the land.