Washington County Jeff Williams, Washington County Tax Assessor David Ruff, Washington County Ta — Vandiver, J…

Summary

The concurrence agrees that the trial court properly granted summary judgment to the University and should be affirmed, but it reaches that result under a narrower theory of limited implied sovereign immunity from ad valorem taxes. It reasons that the immunity depends on whether the University's parcels are held for a public purpose, that state-owned property is constitutionally presumed to have a public purpose, and that the assessor's speculative affidavit did not rebut that presumption. The concurrence emphasizes that the conclusion is limited to the parcels at issue and does not establish immunity for all University property.