The Indiana Tax Court recently issued a ruling in the case of Convention Headquarters Hotels LLC v. Marion County Assessor, docket number 19T-TA-00021. The court's decision, delivered by Judge Justin L. McAdam on September 3, 2026, addressed a request from Convention Headquarters Hotels (CHH) to amend its petition for judicial review after nearly seven years of litigation. The ruling has implications for how property assessments are challenged in Indiana and highlights the complexities of tax law.
The case began in 2019 when CHH filed a petition against the Marion County Assessor, challenging the assessment of its property. The dispute centers on whether the property was assessed fairly and in accordance with constitutional and statutory requirements. CHH alleged that its property was under-assessed compared to similar properties, raising issues of equal protection and due process under the U.S. Constitution, as well as claims under the Indiana Constitution.
Over the years, the case has undergone various stages of litigation, including a bifurcation of the constitutional claims from the valuation claims. This separation allowed the court to focus first on the constitutional issues, which were resolved in a ruling issued on May 24, 2024. The court found that CHH had not demonstrated that its property was treated differently than other commercial properties under construction in Marion County, thus rejecting its constitutional claims.
After the court's ruling, CHH sought to amend its petition to include new claims regarding the uniformity and equalization of its property assessment. The proposed amendments aimed to broaden the valuation count and introduce two new counts challenging the assessment's compliance with Indiana law. However, the Marion County Assessor opposed these new claims, arguing that they were untimely and would prejudice the Assessor's ability to defend against them.
In its ruling, the court granted some of CHH's requests while denying others. The court allowed CHH to amend Count VI, which pertains to the market value-in-use of the property, but denied the addition of proposed Counts VII and VIII, which sought to introduce new claims regarding uniformity and equalization. The court stated, "The addition of Counts VII and VIII has been unduly delayed and would prejudice the Assessor." This highlights the importance of timely claims in legal proceedings.
The court's decision emphasized that CHH failed to provide a convincing justification for the delay in seeking these amendments. The court noted that the proposed claims could have been raised earlier in the litigation, particularly before the bifurcation of the case. Additionally, the court found that allowing the new claims would unduly burden the Assessor, who had already prepared to defend against the original claims.
Moving forward, this ruling sets a precedent regarding the timing and nature of amendments in tax assessment cases. It underscores the need for parties to present all relevant claims in a timely manner to avoid complications later in the litigation process. The decision may also influence how similar cases are handled in the future, particularly in terms of the balance between judicial efficiency and the rights of property owners.
As for what’s next, CHH is required to file an amended petition conforming to the court's order within fifteen days. The parties must also submit a joint proposed case management plan within thirty days to address any remaining discovery and dispositive motions related to the claims that are still active. This ongoing litigation reflects the complexities of property tax law and the challenges that arise when property owners seek to contest assessments.