Johansson v. Miami-Dade County Value Adjustment Board
A pro se taxpayer sought certiorari, mandamus, and prohibition in the circuit court appellate division to quash a VAB Special Magistrate's property valuation recommendation. The Third DCA denied second-tier certiorari, holding the appellate division correctly dismissed for lack of jurisdiction because a value adjustment board is not a 'lower tribunal' subject to circuit court appellate or supervisory authority; the taxpayer's exclusive remedy is an original de novo action against the property appraiser under section 194.171.
Key facts
- Pro se taxpayer sought certiorari, mandamus, and prohibition in the circuit court appellate division to challenge a Value Adjustment Board Special Magistrate's property valuation recommendation.
- The circuit court appellate division dismissed the petition for lack of jurisdiction, and the Third DCA affirmed on second-tier certiorari review.
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Why it matters
The opinion clarifies a recurring jurisdictional trap for property tax practitioners: VAB decisions cannot be attacked by certiorari, mandamus, or prohibition in the circuit court's appellate division, and the… — full analysis with a trial
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