State Tax Day - Current, S.12, Missouri—Property Tax: Constitutionality of Airport Property Valuation Statute Upheld, (Apr 23, 2026)

The owner of a hotel at the Kansas City International airport was allowed to keep its lower property tax valuation after the Missouri Supreme Court affirmed the circuit court’s judgment and upheld the constitutionality of Sec. 137.115.1, RSMo, which governs how county assessors determine the "true value in money" for certain commercial properties located on or within airport boundaries.

The Court held that the school district lacked standing to challenge the tax assessment because it’s interest in potential funding loss did not confer standing to contest another’s property valuation. Standing for this interest may exist when a school district brings a declaratory judgment action to determine its own rights under a statute it alleges is unconstitutional, but not when the school district is challenging the assessed value of another’s property. Consequently, the school district did not have standing to challenge the hotel’s assessment value, and its claims were dismissed.

The county assessor also lacked standing to assert claims under Article I, Secs. 10 (due process/vagueness) and 13 (special privileges) of the Missouri Constitution because political actors, when acting in their official capacities, do not possess those individual constitutional protections. However, the assessor did have standing to challenge the statute under Article X, Secs. 3 and 6, the tax exemption and uniformity provisions of the Constitution. Nevertheless, the Court held that Sec. 137.115.1 neither created an unconstitutional tax exemption nor violated the uniformity clause. Section 137.115.1 does not create a tax exemption. Instead, it lawfully prescribes a valuation method—requiring assessors to deduct qualifying construction and improvement costs from the otherwise applicable fair market value for airport-boundary properties. The statute affects how value is calculated, not whether tax is owed, and thus does not exempt property from taxation. The uniformity clause requires uniform tax rates within a class of property, not uniform property values and valuation methods. Because the Missouri Constitution expressly allows the legislature to fix valuation methods by law, applying a distinct valuation method to properties within airport boundaries does not violate uniformity. Thus, the circuit court’s judgment was affirmed.

Cox v. Grady Hotel Investments, LLC, Supreme Court of Missouri, No. SC101131, April 21, 2026, ¶204-671