exemption clause (New Jersey) · Go Syfert
← New Jersey issues

exemption clause in New Jersey

37 New Jersey opinions name it 4 courts 1900–2025 3 in the last five years

The cases below were cited by New Jersey courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (16)

CaseFollowedCited
New Jersey State League of Municipalities v. Kimmelmangreen
nj · 1987 · cited in 3 New Jersey opinions naming this issue, 1989–2003
2 sentences

2003After reviewing the history of the constitutional provisions, particularly the Uniformity Clause, the Court concluded that the Uniformity Clause prevailed over the exemption clause: Given that the constitutional focus of the delegates on the taxation of real estate was upon a judicial decision that had sustained the power of the Legislature, prior to the 1947 Constitutional Convention, to allow for the preferential taxation of real estate based on the classification of the industry, and given that the single galvanizing event that brought about agreement on a tax article was a compromise that

1989The Supreme Court, in Kimmelman , stated: Given ... the apparent purpose of providing that real property dedicated to municipal tax purposes should never be taxed at an unequal burden, we cannot conclude that the delegates intended that the Legislature could achieve, by the exemption clause, what could not be done under the constitutional restraints imposed upon it. [Id. at 436, 522 A.2d 430 ] Attempts by the Legislature to adversely affect the uniformity of assessment and taxation of real property by exemption or classification of property have generally been nullified.

33
Pingry Corp. v. Township of Hillsidegreen
nj · 1966 · cited in 2 New Jersey opinions naming this issue, 2019–2025
2 sentences

2025Pingry Corp. v. Hillside, 46 N.J. 457, 463 (1966). 1.

2019Pingry Corp. v. Hillside, 46 N.J. 457, 463 (1966). 1.

22
2nd Roc-Jersey Associates v. Town of Morristowngreen
nj · 1999 · cited in 2 New Jersey opinions naming this issue, 2003–2023
2 sentences

2023Town of Secaucus v. Hudson County Bd. of Taxation, 133 N.J. 482, 503 (1993); see also 2nd Roc- Jersey Assocs. v. Town of Morristown, 158 N.J. 581, 590 (1999) (concluding that the “Legislature may exempt certain property from the Uniformity Clause either by general laws or for the specified purposes enumerated in the exemption clause.”).

2023Town of Secaucus v. Hudson County Bd. of Taxation, 133 N.J. 482, 503 (1993); see also 2nd Roc- Jersey Assocs. v. Town of Morristown, 158 N.J. 581, 590 (1999) (concluding that the “Legislature may exempt certain property from the Uniformity Clause either by general laws or for the specified purposes enumerated in the exemption clause.”).

12
New Jersey Carpenters Apprentice Training & Education Fund v. Borough of Kenilworthgreen
nj · 1996 · cited in 2 New Jersey opinions naming this issue, 2020–2022
2 sentences

2022The conundrum faced by the taxpayer in this case is that while the comingling of the housing and treatment supports the establishment of the exemption in the first instance, the same comingling may be fatal to an exemption claim when it involves excessive entanglement with a profit- making endeavor. 4 Id. at 24 . 4 To be clear, this case does not address the scenario in which CSLRs such as those operated by Hansen House operate in conjunction with a not-for-profit treatment provider. -7- As to benefitting a for-profit endeavor, another decision of the New Jersey Supreme Court, New Jersey Carpe

2020Fund v. Borough of Kenilworth , 147 N.J. 171, 173-74 (1996), involved the exemption claim for the building owned and operated by a carpenters training and education fund.

12
Switz v. Kingsleygreen
nj · 1962 · cited in 2 New Jersey opinions naming this issue, 1996–2003
2 sentences

1996Legislature could achieve, by the exemption clause, what could not be done under the constitutional restraints imposed upon it Lby the Uniformity Clause]”); Switz v. Kingsley, 37 N.J. 566, 585 , 182 A.2d 841 (1962) (“[w]e need not delay to consider the suggestion that this provision creates but a ‘rebuttable’ presumption, or that the Legislature had in mind such ‘... value’ as could not be considered in any event.”); New Jersey Turnpike Auth. v. Washington Tp., 16 N.J. 38, 45 , 106 A.2d 4 (1954) (“classification^] ... for exemption ... based ... upon the status or vocation or avocation of [the

1996Legislature could achieve, by the exemption clause, what could not be done under the constitutional restraints imposed upon it Lby the Uniformity Clause]”); Switz v. Kingsley, 37 N.J. 566, 585 , 182 A.2d 841 (1962) (“[w]e need not delay to consider the suggestion that this provision creates but a ‘rebuttable’ presumption, or that the Legislature had in mind such ‘... value’ as could not be considered in any event.”); New Jersey Turnpike Auth. v. Washington Tp., 16 N.J. 38, 45 , 106 A.2d 4 (1954) (“classification^] ... for exemption ... based ... upon the status or vocation or avocation of [the

12
Town of Secaucus v. Hudson County Board of Taxationgreen
nj · 1993 · cited in 1 New Jersey opinions naming this issue, 2023–2023
2 sentences

2023Town of Secaucus v. Hudson County Bd. of Taxation, 133 N.J. 482, 503 (1993); see also 2nd Roc- Jersey Assocs. v. Town of Morristown, 158 N.J. 581, 590 (1999) (concluding that the “Legislature may exempt certain property from the Uniformity Clause either by general laws or for the specified purposes enumerated in the exemption clause.”).

2023Town of Secaucus v. Hudson County Bd. of Taxation, 133 N.J. 482, 503 (1993); see also 2nd Roc- Jersey Assocs. v. Town of Morristown, 158 N.J. 581, 590 (1999) (concluding that the “Legislature may exempt certain property from the Uniformity Clause either by general laws or for the specified purposes enumerated in the exemption clause.”).

11
Blair Academy v. Blairstown Tp.green
njsuperctappdiv · 1967 · cited in 1 New Jersey opinions naming this issue, 2019–2019
1 sentence

2019See Blair Academy v. Blairstown Twp., 95 N.J.

11
Chester Theatre Group v. Bor. of Chestergreen
njsuperctappdiv · 1971 · cited in 1 New Jersey opinions naming this issue, 2019–2019
1 sentence

2019The cluster of abstract concepts themselves suggests that, at most, only a descriptive definition is contemplated.” Chester Theatre Grp. of Black River Playhouse v. Borough of Chester, 115 N.J.

11
Wellington v. Township of Hillsboroughgreen
njtaxct · 2012 · cited in 1 New Jersey opinions naming this issue, 2017–2017
1 sentence

2017Tax 264, 267-268 (Tax 1980)(holding that with respect to N.J.S.A. 54:4-4.4, “the assessor’s failure to obtain the statement does not vitiate the exemption otherwise allowable.”); accord Wellington v. Township of Hillsborough, 27 N.J.

11
Emanuel Missionary Baptist Church v. City of Newarkgreen
njtaxct · 1980 · cited in 1 New Jersey opinions naming this issue, 2017–2017
1 sentence

2017Tax 192, 197 (Tax 1981)(holding that the filing of an exemption claim under N.J.S.A. 54:4-4.4 “is not a condition precedent to the allowance of an exemption under N.J.S.A. 54:4-3.6.”) Emanuel Missionary Baptist Church v. City of Newark, 1 N.J.

11
Aetna Burglar & Fire Alarm Co. v. Director, Division of Taxationgreen
njtaxct · 1997 · cited in 1 New Jersey opinions naming this issue, 2012–2012
1 sentence

2012As a general rule, “[e]ourts have recognized the Director’s expertise in the highly specialized and technical area of taxation.” Aetna Burglar & Fire Alarm Co. v. Director, Div. of Taxation, 16 N.J.Tax 584, 589 (Tax 1997) (citing Metromedia, Inc. v. Director, Div. of Taxation, 97 N.J. 313, 327 , 478 A.2d 742 (1984)).

11
Paper Mill Playhouse v. Township of Millburngreen
njtaxct · 1984 · cited in 1 New Jersey opinions naming this issue, 2001–2001
1 sentence

2001It reasoned that the exemption at bar was consistent with the policy behind N.J.S.A. 54:4-3.6, in that it would not interfere with the preparation of the municipal budget. 6 Id. at 86-87.

11
New Jersey Turnpike Authority v. Township of Washingtongreen
nj · 1954 · cited in 1 New Jersey opinions naming this issue, 1996–1996
2 sentences

1996Legislature could achieve, by the exemption clause, what could not be done under the constitutional restraints imposed upon it Lby the Uniformity Clause]”); Switz v. Kingsley, 37 N.J. 566, 585 , 182 A.2d 841 (1962) (“[w]e need not delay to consider the suggestion that this provision creates but a ‘rebuttable’ presumption, or that the Legislature had in mind such ‘... value’ as could not be considered in any event.”); New Jersey Turnpike Auth. v. Washington Tp., 16 N.J. 38, 45 , 106 A.2d 4 (1954) (“classification^] ... for exemption ... based ... upon the status or vocation or avocation of [the

1996Legislature could achieve, by the exemption clause, what could not be done under the constitutional restraints imposed upon it Lby the Uniformity Clause]”); Switz v. Kingsley, 37 N.J. 566, 585 , 182 A.2d 841 (1962) (“[w]e need not delay to consider the suggestion that this provision creates but a ‘rebuttable’ presumption, or that the Legislature had in mind such ‘... value’ as could not be considered in any event.”); New Jersey Turnpike Auth. v. Washington Tp., 16 N.J. 38, 45 , 106 A.2d 4 (1954) (“classification^] ... for exemption ... based ... upon the status or vocation or avocation of [the

11
Christy v. City of Newarkgreen
nj · 1986 · cited in 1 New Jersey opinions naming this issue, 1989–1989
11
Maplewood v. Tannenhausgreen
njsuperctappdiv · 1960 · cited in 1 New Jersey opinions naming this issue, 1968–1968
11
In Re Smallbonegreen
cal · 1940 · cited in 1 New Jersey opinions naming this issue, 1953–1953
11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in New Jersey. Read the followed side critically anyway.

Also cited on this issue (37)

CaseCitedYears
Sisters of Charity v. Cory green
nj · 1907
2 sentences

2015In granting the exemption, the court employed a liberal application of the exemption standard that it would later question and distinguish in Sisters of Charity v. Thompson, 72 N.J.L. 426 , 61 A. 387 (Sup.Ct.1905), which it ultimately retracted in Sisters of Charity v. Cory, 73 N.J.L. 699 , 65 A. 500 (E. & A.1907).

2015In granting the exemption, the court employed a liberal application of the exemption standard that it would later question and distinguish in Sisters of Charity v. Thompson, 72 N.J.L. 426 , 61 A. 387 (Sup.Ct.1905), which it ultimately retracted in Sisters of Charity v. Cory, 73 N.J.L. 699 , 65 A. 500 (E. & A.1907).

21977–2015
The Presbyterian Homes v. Division of Tax Appeals green
nj · 1970
2 sentences

2007Moreover, the Supreme Court of New Jersey has soundly rejected a similar assertion made in support of the exemption claim of another facility for the elderly that provided “luxurious retirement facilities to those who are able to pay.” Presbyterian Homes, supra, 55 N.J. at 289 , 261 A.2d 143 .

2007Moreover, the Supreme Court of New Jersey has soundly rejected a similar assertion made in support of the exemption claim of another facility for the elderly that provided “luxurious retirement facilities to those who are able to pay.” Presbyterian Homes, supra, 55 N.J. at 289 , 261 A.2d 143 .

21970–2007
International Schools Services, Inc. v. West Windsor Township green
nj · 2011
1 sentence

2022The conundrum faced by the taxpayer in this case is that while the comingling of the housing and treatment supports the establishment of the exemption in the first instance, the same comingling may be fatal to an exemption claim when it involves excessive entanglement with a profit- making endeavor. 4 Id. at 24 . 4 To be clear, this case does not address the scenario in which CSLRs such as those operated by Hansen House operate in conjunction with a not-for-profit treatment provider. -7- As to benefitting a for-profit endeavor, another decision of the New Jersey Supreme Court, New Jersey Carpe

12022–2022
Mega Care, Inc. v. Union Township green
njtaxct · 1996
1 sentence

2018Tax 174, 181 (Tax 1996) (rejecting a view “that to determine whether a claimant is organized for an exempt purpose, its operations are to be reviewed,” since an entity’s organization purpose is “plainly distinct” from its “operations,” and the statute does not mandate an “entity-level operational test in the hospital . . . exemptions”). 11 The court granted partial summary judgment denying the exemption claim because the non-profit subsidiary nursing home’s “certificate of incorporation did not specifically limit its activities to those conducted in support of and integration with the [parent]

12018–2018
McDonnell Douglas Corp. v. Green green
scotus · 1973
1 sentence

2018It applied the exemption to the analysis for LAD claims stated in McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973), and concluded that plaintiff could not establish a prima facie case of discrimination.

12018–2018
Sisters of Charity of St. Elizabeth v. Thompson neutral
nj · 1905
2 sentences

2015In granting the exemption, the court employed a liberal application of the exemption standard that it would later question and distinguish in Sisters of Charity v. Thompson, 72 N.J.L. 426 , 61 A. 387 (Sup.Ct.1905), which it ultimately retracted in Sisters of Charity v. Cory, 73 N.J.L. 699 , 65 A. 500 (E. & A.1907).

2015In granting the exemption, the court employed a liberal application of the exemption standard that it would later question and distinguish in Sisters of Charity v. Thompson, 72 N.J.L. 426 , 61 A. 387 (Sup.Ct.1905), which it ultimately retracted in Sisters of Charity v. Cory, 73 N.J.L. 699 , 65 A. 500 (E. & A.1907).

12015–2015
Metromedia, Inc. v. Director, Division of Taxation green
nj · 1984
2 sentences

2012As a general rule, “[e]ourts have recognized the Director’s expertise in the highly specialized and technical area of taxation.” Aetna Burglar & Fire Alarm Co. v. Director, Div. of Taxation, 16 N.J.Tax 584, 589 (Tax 1997) (citing Metromedia, Inc. v. Director, Div. of Taxation, 97 N.J. 313, 327 , 478 A.2d 742 (1984)).

2012As a general rule, “[e]ourts have recognized the Director’s expertise in the highly specialized and technical area of taxation.” Aetna Burglar & Fire Alarm Co. v. Director, Div. of Taxation, 16 N.J.Tax 584, 589 (Tax 1997) (citing Metromedia, Inc. v. Director, Div. of Taxation, 97 N.J. 313, 327 , 478 A.2d 742 (1984)).

12012–2012
Paper Mill Playhouse v. Millburn Township green
nj · 1984
2 sentences

2009In her opinion, the judge examined PHP’s exemption claim in accordance with the three criteria set forth in N.J.S.A. 54:4-3.6 and Paper Mill Playhouse v. Millbum Township, 95 N.J. 503 , 472 A.2d 517 (1984). 23 N.J.

2009In her opinion, the judge examined PHP’s exemption claim in accordance with the three criteria set forth in N.J.S.A. 54:4-3.6 and Paper Mill Playhouse v. Millbum Township, 95 N.J. 503 , 472 A.2d 517 (1984). 23 N.J.

12009–2009
Hunterdon Medical Center v. Readington Township green
njtaxct · 2005
1 sentence

2009Id. at 334-41 .

12009–2009
Presbyterian Home at Pennington, Inc. v. Pennington Borough green
njtaxct · 2007
1 sentence

2009In her opinion, the judge examined PHP’s exemption claim in accordance with the three criteria set forth in N.J.S.A. 54:4-3.6 and Paper Mill Playhouse v. Millbum Township, 95 N.J. 503 , 472 A.2d 517 (1984). 23 N.J.

12009–2009
Alpine Country Club v. Borough of Demarest green
njsuperctappdiv · 2002
2 sentences

2007Therefore, the Tax Court judge, using his "special expertise", Alpine Country Club v. Borough of Demarest, 354 N.J.Super. 387, 390 , 807 A. 2d 257 (App.Div.2002), formulated a logical, practical and viable standard, which is well-reasoned, supported by case law, and which we expressly endorse.

2007Therefore, the Tax Court judge, using his "special expertise", Alpine Country Club v. Borough of Demarest, 354 N.J.Super. 387, 390 , 807 A. 2d 257 (App.Div.2002), formulated a logical, practical and viable standard, which is well-reasoned, supported by case law, and which we expressly endorse.

12007–2007
City of Pittsburgh v. Board of Property Assessment green
pacommwct · 1989
2 sentences

2005Clubs of California for Fair Competition v. Kroger, 7 Cal.App. 4th 709 , 9 Cal.Rptr.2d 247 (1992); City of Pittsburgh v. Board of Property Assessment, Appeals and Review, 129 Pa.Cmwlth. 69 , 564 A.2d 1026 (1989).

2005Clubs of California for Fair Competition v. Kroger, 7 Cal.App. 4th 709 , 9 Cal.Rptr.2d 247 (1992); City of Pittsburgh v. Board of Property Assessment, Appeals and Review, 129 Pa.Cmwlth. 69 , 564 A.2d 1026 (1989).

12005–2005
Clubs of California for Fair Competition v. Kroger green
calctapp · 1992
2 sentences

2005Clubs of California for Fair Competition v. Kroger, 7 Cal.App. 4th 709 , 9 Cal.Rptr.2d 247 (1992); City of Pittsburgh v. Board of Property Assessment, Appeals and Review, 129 Pa.Cmwlth. 69 , 564 A.2d 1026 (1989).

2005Clubs of California for Fair Competition v. Kroger, 7 Cal.App. 4th 709 , 9 Cal.Rptr.2d 247 (1992); City of Pittsburgh v. Board of Property Assessment, Appeals and Review, 129 Pa.Cmwlth. 69 , 564 A.2d 1026 (1989).

12005–2005
YMCA v. Dept. of Rev. green
or · 1989
2 sentences

2005The Oregon Supreme Court denied the exemption claim, Young Men's Christian Association of Columbia-Willamette v. Department of Revenue, 308 Or. 644 , 784 P.2d 1086 (1989), but courts in California and Pennsylvania have granted the exemption to facilities similar to that at issue in the Oregon decision.

2005The Oregon Supreme Court denied the exemption claim, Young Men's Christian Association of Columbia-Willamette v. Department of Revenue, 308 Or. 644 , 784 P.2d 1086 (1989), but courts in California and Pennsylvania have granted the exemption to facilities similar to that at issue in the Oregon decision.

12005–2005
Schizophrenia Foundation v. Township of Montgomery green
njsuperctappdiv · 1984
1 sentence

1998It relies on the decision in Schizophrenia Foundation of N.J. v. Montgomery Tp., 6 N.J.Tax 439 (App.Div.1984), to the effect that the use of the property as of completion is determinative when an exemption claim is made with respect to an added assessment.

11998–1998
Town of Secaucus v. Hudson County Board of Taxation neutral
njsuperctappdiv · 1992
2 sentences

1993Both the trial court and the Appellate Division found N.J.S.A. 18A:54-37 to have violated the uniformity clause, although for different reasons. supra, 255 N.J.

1993Both the trial court and the Appellate Division found N.J.S.A. 18A:54-37 to have violated the uniformity clause, although for different reasons, supra, 255 N.J.Super. at 669 , 605 A.2d 1151 .

11993–1993
Town of Morristown v. Woman's Club green
nj · 1991
2 sentences

1993The Court, however, has declined to take the listing of the exemption clause literally (i.e., confined to property used exclusively for religious, educational, charitable, or cemetery purposes, by non-profit organizations), and instead has looked to "whether the exemption is based on a permissible classification and if so, whether the classification serves a public purpose." Morristown, supra, 124 N.J. at 614 , 592 A. 2d 216 .

1993The Court, however, has declined to take the listing of the exemption clause literally (i.e., confined to property used exclusively for religious, educational, charitable, or cemetery purposes, by non-profit organizations), and instead has looked to "whether the exemption is based on a permissible classification and if so, whether the classification serves a public purpose." Morristown, supra, 124 N.J. at 614 , 592 A. 2d 216 .

11993–1993
Institute of Holy Angels v. Borough of Fort Lee green
nj · 1910
11982–1982
State v. Heyer neutral
nj · 1916
11981–1981
Stone v. Ward green
ca9 · 1980
11981–1981
Stone v. Stone green
cand · 1978
11981–1981
Borough of Harvey Cedars v. Sisters of Charity of Saint Elizabeth green
njsuperctappdiv · 1978
11980–1980
Monmouth Medical Center v. City of Long Branch green
nj · 1977
11980–1980
International Missions, Inc. v. Lincoln Park green
njsuperctappdiv · 1965
11980–1980
Bor. Cresskill v. Nor. Val. Evan. Church green
njsuperctappdiv · 1973
11980–1980
Township of Teaneck v. Lutheran Bible Institute green
nj · 1955
11980–1980
City of Long Branch v. Monmouth Medical Center green
njsuperctappdiv · 1976
11980–1980
Princeton Tp. v. Tenacre Foundation green
njsuperctappdiv · 1961
11980–1980
United States v. Jeffers green
scotus · 1951
11964–1964
McDonald v. United States green
scotus · 1948
11964–1964
Stein v. Felden green
njsuperctappdiv · 1952
11962–1962
Glidear v. Charles green
njsuperctappdiv · 1951
11962–1962
Densel v. Atlanta Mercantile Co. green
idaho · 1909
11953–1953
United States Trust Co. v. Helvering green
scotus · 1939
11944–1944
Bailey v. Wood green
mass · 1909
11915–1915
Bailey v. Wood green
· 1909
11915–1915
Matter of Estate of Prime green
· 1893
11900–1900

Statutes the citing opinions construe

NJ § N.J. Stat. § 54:4-3.6 (8) NJ § N.J. Stat. § 54:4-23 (3) NJ § N.J. Stat. § 54:4-4.4 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 76 (1893–2026) PA 39 (1930–2019) IL 38 (1874–2023) NJ 37 (1900–2025) NY 32 (1892–2024) TX 30 (1925–2019) WA 27 (1895–2025) OH 23 (1926–2026) FL 20 (1882–2024) AL 20 (1884–2004) MI 19 (1931–2023) AR 18 (1898–2024) MD 17 (1929–2016) OK 15 (1929–2023) CT 14 (1912–2026) TN 14 (1877–2018) MO 13 (1893–2009) OR 12 (1916–2022) NM 11 (1941–2015) LA 11 (1936–2007) MA 10 (1930–2012) IA 9 (1928–2025) IN 9 (1980–2016) NC 9 (1921–2016) VA 8 (1912–2016) RI 8 (1897–2008) GA 8 (1935–2022) MS 8 (1995–2016) KS 8 (1895–2022) CO 7 (1906–2015) WV 7 (1960–2026) NE 7 (1922–2024) MT 7 (1929–2021) MN 6 (1877–1996) UT 6 (1991–2024) WI 6 (1928–2023) VT 5 (1929–2005) NV 4 (1977–2017) DC 4 (1976–2024) KY 4 (1921–2017) ME 3 (2004–2016) SD 3 (1894–1989) SC 3 (1988–2024) PR 2 (1929–1950) WY 2 (1987–2004) HI 2 (1893–1985) ID 2 (1958–2014) DE 2 (1995–2021)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

← Caselaw search · G Cite Topics · Brief Check