McNally v. Township of Teaneck

New Jersey state law permitted municipalities to assess properties that were enriched by local improvements. The law prohibited the total assessment amount from being more than the municipality paid for the improvements. Further, no individual assessment against any individual property could be greater than the increased value of that property resulting from the improvements. Pursuant to this state law, the Township of Teaneck (defendant) levied special assessments against landowners who lived near roads that were improved by paving and curb installation. The assessment amounts were based on the size of a property’s frontage (front-foot basis). The assessors then visually inspected each property to ensure the appropriateness of each assessment. This front-foot-basis method resulted in different ratios of assessments charged to increased property values. Despite these different ratios, however, none of the individual assessments were higher than the increased value of an individual property. Further, the total amount of the assessments was not more than the town paid for the improvements. The landowners (plaintiffs) sued the town, asserting that the assessment did not take sufficient account of the different benefits among different landowners. The trial court ruled in the landowners’ favor and invalidated the assessments. The town appealed.