Pinghua Zhao, Plaintiff-Petitioner v. Karen L. Montoya, Bernalillo County Assessor, Defendant-Respondent; and Gregg…

Summary

The court upheld the statutory acquisition-value property-tax scheme against the challenges that it created an unauthorized taxpayer classification and violated the New Mexico Constitution's equal-and-uniform requirement. It held that the statutory distinction is based on the nature of residential property and the timing of an ownership transfer, not on an impermissible personal characteristic of taxpayers, and that the scheme rationally furthers legitimate interests in neighborhood stability and preservation. The court reversed the Court of Appeals' interpretation equating ownership with owner-occupancy while otherwise affirming its result.