The New Jersey Tax Court has ruled in favor of Ameream LLC, the developer of the American Dream Mall, regarding a tax assessment freeze that will affect property tax calculations for the next two years. This decision comes after a dispute with the Borough of East Rutherford over the application of the Freeze Act, a law that limits how much property assessments can be raised after a successful tax appeal. The ruling is significant as it clarifies the application of the Freeze Act to properties under Payments in Lieu of Taxes (PILOT) agreements.

The case, Ameream LLC v. Borough of East Rutherford, was decided on October 30, 2026, under docket number 007852-2025. The court found that the protections of the Freeze Act apply to the American Dream Mall, despite its unique tax status. This ruling means that the Borough cannot raise the mall's property assessment for the next two years, providing financial stability for the developer.

Background

Ameream LLC is the owner and developer of the American Dream Mall, a large retail and entertainment complex located in East Rutherford, New Jersey. The mall has been a significant development project in the state, attracting attention for its size and the variety of attractions it offers. In July 2025, the Tax Court ruled that the cumulative assessment for the mall's properties should be reduced to $1,653,960,000.

Following this judgment, the Borough of East Rutherford increased the cumulative assessments to $1,899,992,100 for the 2026 tax year. In response, Ameream LLC filed a motion to freeze the 2025 judgment, arguing that the Freeze Act should apply to their case. The Borough, along with US Bank and Trust Company, which served as amicus curiae, opposed the motion, claiming that the mall's PILOT status and the Borough's reassessment practices disqualified it from Freeze Act protections.

The Ruling

The Tax Court ruled that the Freeze Act does indeed apply to the American Dream Mall, stating, "The Freeze Act is a statute of mandatory and automatic application, and the burden to defeat it falls on the taxing district." The court emphasized that the PILOT agreement does not prevent the application of the Freeze Act, as it requires the Borough to maintain assessments as if the properties were subject to conventional property taxes.

Judge Gilmore noted that there was no substantial evidence presented by the Borough or US Bank to demonstrate a significant change in the value of the properties that would justify an increase in assessment. The court stated, "Freezing the 2025 judgment for 2026 therefore does not leave the properties carrying outdated assessed values while the rest of the district moves on." This ruling effectively protects Ameream LLC from increased property taxes for the next two years.

Impact

This ruling has important implications for property tax assessments in New Jersey, particularly for properties under PILOT agreements. It confirms that the Freeze Act can provide protections even when properties do not pay conventional property taxes. This decision may encourage other property owners under similar agreements to seek similar protections, knowing that the courts may uphold the Freeze Act's provisions.

Furthermore, the ruling sets a precedent regarding the interpretation of the Freeze Act in relation to yearly reassessments. It clarifies that routine annual updates do not constitute a complete reassessment that would negate the protections offered by the Freeze Act. This could impact how municipalities approach property assessments in the future, especially in districts with properties subject to PILOT agreements.

What's Next

While the court's decision is final for the current case, there is always the possibility of an appeal. However, details regarding any potential appeals were not available in the court filing. As of now, there are no related cases pending that directly address the same issues, but the implications of this ruling may influence future tax assessment disputes in New Jersey.