Wednesday, October 28, 2026

Tax Injunction Act Bars Federal Court Relief for Denial of Property Tax Exemption for Church Property

In Jordan v. Henriquez, (MD FL, Oct. 26, 2026), a Florida federal district court held that the Tax Injunction Act requires it to dismiss a suit by the Senior Pastor of a church challenging the denial of a property tax exemption for parsonage property which was rented out and whose income went back to the church. The Tax Injunction Act bars federal jurisdiction where the suit seeks to enjoin, suspend or restrain a tax assessment.  The court rejected plaintiff's argument that a determination of whether property is entitled to a religious exemption does not amount to an “assessment.” Plaintiff also alleged that the county appraiser applied more lenient standards to Catholic religious organizations than to Protestant groups.The court said in part:

... [E]ven if “assessment” in these circumstances were limited to the “official recording of taxpayer liability” as Plaintiff argues, Plaintiff’s requested relief would nevertheless enjoin, suspend, or restrain the assessment of taxes. Plaintiff asks the Court to prevent Defendant from denying any applications for religious exemptions....

Even if the Tax Injunction Act did not preclude jurisdiction in this case, Plaintiff’s claims are due to be dismissed on comity grounds. The comity doctrine is a doctrine of abstention that reflects the “belief that the National Government will fare best if the States and their institutions are left free to perform their functions in separate ways.”...