Florida Statute 194.3015 - Full Text and Legal Analysis

The 2025 Florida Statutes

Title XIV
TAXATION AND FINANCE

Chapter 194
ADMINISTRATIVE AND JUDICIAL REVIEW OF PROPERTY TAXES

View Entire Chapter

194.3015 Burden of proof.—

(1) It is the express intent of the Legislature that a taxpayer shall never have the burden of proving that the property appraiser’s assessment is not supported by any reasonable hypothesis of a legal assessment. All cases establishing the every-reasonable-hypothesis standard were expressly rejected by the Legislature on the adoption of chapter 97-85, Laws of Florida. It is the further intent of the Legislature that any cases published since 1997 citing the every-reasonable-hypothesis standard are expressly rejected to the extent that they are interpretative of legislative intent.

(2) This section is intended to clarify existing law and apply retroactively.

History.—s. 2, ch. 2009-121.

F.S. 194.3015 on Google Scholar

F.S. 194.3015 on CourtListener

Amendments to 194.3015

Annotations, Discussions, Cases:

Cases Citing Statute 194.3015

Total Results: 1 | Sort by: Relevance | Newest First

Copy

CVS EGL Fruitville Sarasota FL, LLC v. Todora, 124 So. 3d 289 (Fla. 2d DCA 2013).

Published | Florida 2nd District Court of Appeal | 2013 WL 5225769, 2013 Fla. App. LEXIS 14817

...2d DCA 2001) (emphasis added) (citations omitted). And the supreme court thereafter approved this legal analysis from Todora thus espousing the “any-reasonable-hypothesis” standard. See Mazourek v. Wal-Mart Stores, Inc., 831 So.2d 85, 90-91 (Fla.2002). In 2009, the Florida Legislature enacted 194.3015, Fla. Stat. (2009), to redress the courts’ continued application of the “any-reasonable-hypothesis” standard in reviewing challenges to the property appraiser’s *292 assessments. See ch. 09-121, § 2, at 1528, Laws of Fla. Section 194.3015 provides as follows: (1) It is the express intent of the Legislature that a taxpayer shall never have the burden of proving that the property appraiser’s assessment is not supported by any reasonable hypothesis of a legal assessment....

...resumption of correctness remained and whether CVS met its corresponding burden of proving that the assessment was in excess of just value. This was error because that standard has been abrogated by section 194.301 as clarified by the legislature in section 194.3015....