Yeshivath Shearith Hapletah v. Assessor of the Town of Fallsburg, 79 N.Y.2d 244 (1992)
The term “exclusively” in the context of religious tax exemptions under RPTL 420-a(1)(a) is broadly defined to mean “principal” or “primary,” such that uses merely auxiliary or incidental to the main and exempt purpose will not defeat the exemption.
Summary
Yeshivath Shearith Hapletah, a religious corporation, sought a full tax exemption for its Woodbourne facility, used for religious education programs. The assessor partially denied the exemption, deeming certain housing units and land taxable. The New York Court of Appeals held that the entire property was tax-exempt under RPTL 420-a(1)(a), because the housing and recreational areas were reasonably incidental to the primary religious purpose of the facility. The Court emphasized a broad interpretation of “exclusively” to encourage religious institutions.
Facts
Yeshivath Shearith Hapletah, a religious corporation, operates a school in Brooklyn and religious educational programs at a 31-acre facility in Fallsburg, NY, called Woodbourne. Woodbourne is primarily used during the summer. Approximately 450 students receive religious instruction daily. The facility includes a main building with a kitchen, dining room, bath, recreational facilities, classrooms, synagogues, dormitories, 64 bungalows, and 6 trailers. These housing units are occupied by rabbis, teachers, staff, and their families, all participating in the religious programs. One trailer houses a caretaker who provides maintenance and security year-round. The religious instruction programs are exclusively for members of the yeshivah.
Procedural History
The property was initially tax-exempt after a 1982 declaratory judgment. In 1987 and 1988, the assessor returned portions of the property to the tax rolls. The Yeshivah applied for exemption under RPTL 420-a(1)(a), which the assessor partially granted. The Yeshivah commenced Article 7 proceedings challenging the partial denial. The Supreme Court dismissed the petitions. The Appellate Division reversed, granting the petitions and declaring the property fully exempt. The Assessor appealed to the New York Court of Appeals.
Issue(s)
Whether the housing facilities (bungalows, trailers) used by staff, teachers, rabbis, and families, and the ten acres of wooded land, at the Yeshivath Shearith Hapletah’s Woodbourne facility are used “exclusively” for religious purposes, thus entitling the entire property to a full tax exemption under Real Property Tax Law § 420-a(1)(a).
Holding
Yes, because the housing and recreational facilities are necessary and reasonably incidental to the primary purpose of providing rigorous religious and educational instruction at the Yeshivah. The caretaker’s residence is also tax exempt because the caretaker’s presence ensures the maintenance and security of the facility which serves the religious purposes of the organization.
Court’s Reasoning
The Court emphasized that RPTL 420-a(1)(a) exempts property owned by a religious organization and used exclusively for religious purposes. The term “exclusively” is interpreted broadly to mean “principal” or “primary.” Uses merely auxiliary or incidental to the main purpose will not defeat the exemption. The test for tax exemption is whether the particular use is reasonably incidental to the primary purpose of the facility. Supplying living accommodations for hospital personnel and their immediate families is a hospital purpose (Matter of St. Luke’s Hosp. v Boyland, 12 NY2d 135, 141). The uncontradicted evidence demonstrated that the housing facilities are occupied by staff, teachers, rabbis, and families, members of which are either students at the yeshivah or parents of students too young to attend without supervision. The Court distinguished Matter of St. Agnes Church v Daby (148 AD2d 31), because that case involved RPTL 462, concerning residences for clergy. The Court found that the recreational use of the wooded area by the students was incidental to the primary religious purpose.