Background
Bond County taxpayers challenged the 2022 property-tax assessments, a general or quadrennial assessment year. They alleged that the county published the assessments too late—on June 23, 2023—and sought to have their tax liabilities reset to 2021 assessment values, with refunds for overpayments.
The undisputed record showed that the assessor completed the 2022 assessments on June 16, 2023, and published them one week later. The circuit court granted summary judgment to County Treasurer Colleen Camp, concluding that the cited publication deadline did not invalidate the general-year assessments.
The Court’s Holding
The appellate court affirmed. Under section 12-10 of the Illinois Property Tax Code, publication in a general assessment year is required “as soon as” the assessor completes the assessment; the December 31 deadline applies to years other than general assessment years. Because the assessments were published shortly after their June 2023 completion, they were timely.
The court relied on Illinois Supreme Court decisions interpreting materially similar predecessor language, including People ex rel. Ball v. Anderson and People ex rel. Doerfler v. Lowen. It held that Andrews v. Foxworthy, on which the taxpayers relied, concerned a non-quadrennial year and did not require publication by a fixed date in a general assessment year. The court also noted that statutory savings and curative provisions would preserve the assessments even if a timing defect existed.
Key Takeaways
- For a general or quadrennial assessment year, section 12-10 requires publication when the assessment is completed, not by December 31 of the tax year.
- Predecessor-case interpretations of the publication rule remained applicable because the Property Tax Code did not substantively change the relevant language.
- Taxpayers who do not challenge their property valuations cannot obtain invalidation of assessments solely from the asserted publication-timing defect presented here.
Why It Matters
The decision distinguishes general assessment years from intervening assessment years when applying publication requirements under the Property Tax Code. It also confirms that a publication-timing challenge does not automatically undo an otherwise completed assessment, particularly where the Code’s savings and curative provisions apply.