Park Hill School District, Appellant, v. GRADY HOTEL INVESTMENTS LLC (2026)

The Platte County assessor (“Assessor”) and Park Hill School District (“Park Hill”) appeal the circuit court's judgment holding section 137.115.1 does not violate the Missouri Constitution.¹ Because Assessor lacks standing to bring article I, sections 10 and 13 claims and Park Hill lacks standing for all of its claims, these claims are dismissed. Although Assessor does have standing to challenge section 137.115.1 as violating article X, sections 3 and 6 of the Missouri Constitution, this Court finds no violation. The circuit court's judgment is affirmed.

Background

The controversy in this case revolves around whether the 2016 property tax assessment for the Marriot Hotel located at the Kansas City International Airport (“KCI”) violates the Missouri Constitution. Grady Hotel Investments, LLC, (“Grady”) purchased the hotel in 2015 from Host Hotels & Resorts, L.P., for $8.5 million. Because the hotel lies within airport boundaries, the land remains titled as property of the City of Kansas City (“City”). Grady purchased a possessory interest to the improvements on that parcel—meaning Grady does not own the land but, instead, owns the hotel building situated on airport property.² As a political subdivision of the state, City is exempt from paying property taxes. Mo. Const. art. X, sec. 6. Grady, however, is required by law to pay property taxes on the property improvements, i.e. the hotel building that it owns. Mo. Const. art. X, sec. 4(b); Id. art. X, sec. 4(c). For taxation purposes, real property includes improvements that are permanently affixed to land. Section 137.010(4).³

In the 2016 tax year, Assessor valued the hotel at $11,222,000. Grady appealed this determination to the Platte County Board of Equalization. After a hearing, the Board increased the value of the hotel to $13,447,000. Grady then appealed the Board's decision to the State Tax Commission (“STC”). An STC hearing officer set aside the Board's evaluation and determined the value of the property was $7.3 million. The hearing officer applied section 137.115.1 by taking the price of the sale of the improvements—$8.5 million—less the cost paid toward new construction of the improvements—$1.2 million.⁴ Grady appealed that decision to the full STC. Upon review, the STC determined Grady held a leasehold interest in the hotel and valued the property as the difference between economic rent and the contract rent for use and occupancy of the premises.⁵ As a result, the STC held the property's value was $0.⁶

Assessor appealed the STC's decision to the Platte County circuit court. Park Hill moved to intervene, and the circuit court sustained the motion. After hearing argument about whether Grady held a leasehold or possessory ownership interest, the circuit court reversed the STC's order. The circuit court determined the STC's decision that the property's value was $0 was arbitrary, capricious, and unsupported by law. Specifically, the circuit court found Grady owned the property's improvements, which made the STC's valuation method inapplicable, because it applied only to leasehold interests.

Grady appealed the circuit court's decision.⁷ The court of appeals affirmed the circuit court's decision, holding Grady held an ownership interest, not a leasehold interest.⁸ The court of appeals remanded the case back to the STC.⁹

On remand, an STC hearing officer valued the hotel at $6,139,505 by subtracting from the $8.5 million purchase price the value of personal property, $1,160,495, and the cost of new construction and improvements, $1.2 million. Assessor and Park Hill jointly appealed to the full STC, which affirmed the decision. Both parties sought the circuit court's review.

At the circuit court, Assessor again challenged the constitutional validity of section 137.115.1. Assessor argued the provision violated the Missouri Constitution because the statute: (1) was void for vagueness in violation of article I, section 10; (2) gave Grady an unconstitutional tax exemption in violation of article X, section 6; (3) violated the uniformity provision of article X, section 3; and (4) granted an irrevocable special privilege in violation of article I, section 13. Park Hill mirrored Assessor's article I, section 13, and article X, sections 6 and 3 claims.

The circuit court affirmed the STC's decision. It found section 137.115.1 affected how “true value in money” was determined but did not create an unconstitutional tax exemption under article X, section 6. It also found section 137.115.1 did not violate the uniformity clause because article X, section 3 did not apply to valuations of property. While expressing doubt about both the Assessor's and Park Hill's standing, the circuit court found section 137.115.1 was not vague or ambiguous, or irrational and arbitrary, in violation of article I, section 10. Lastly, the circuit court found section 137.115.1 was not an irrevocable special privilege in violation of article I, section 13 because the legislature had revised the statute several times since its enactment and the legislature had a rational basis to distinguish property located on airport boundaries from property that was not.

Assessor and Park Hill appealed the circuit court's decision to this Court. This Court has exclusive appellate jurisdiction pursuant to article V, section 3 of the Missouri Constitution.

Standard of Review

“While the Court defers to the [STC's] judgment regarding factual matters, it reviews de novo matters of statutory or constitutional interpretation.” Armstrong-Trotwood, LLC v. State Tax Comm'n, 516 S.W.3d 830, 835 (Mo. banc 2017). Statutes are presumed constitutional and must clearly contravene a constitutional provision to be found unconstitutional. State v. League of Women Voters of Mo., No. SC100997, ––– S.W.3d ––––, ––––, 2026 WL 816122, at *3 (Mo. banc Mar. 24, 2026).

Analysis

The issue before this Court is whether section 137.115.1 is constitutional. Before this Court may address the various challenges to the provision's constitutional validity, however, it must first address whether Assessor and Park Hill have standing. Nicholson v. State, No. SC101308, ––– S.W.3d ––––, ––––, 2026 WL 202013, at *3 (Mo. banc Jan. 23, 2026).

I. Standing

To give a court authority to hear a case, a plaintiff must present a justiciable controversy. City of St. Louis v. State, 682 S.W.3d 387, 398 (Mo. banc 2024). “A justiciable controversy exists when [1] the plaintiff has a legally protectable interest at stake, [2] a substantial controversy exists between parties with genuinely adverse interests, and [3] that controversy is ripe for judicial determination.” Id. (alteration omitted) (internal quotation omitted). The first two elements of a justiciable controversy encompass standing. Id.

Standing is a prerequisite to this Court's authority to address substantive issues. Byrne & Jones Enters., Inc. v. Monroe City R-1 Sch. Dist., 493 S.W.3d 847, 851 (Mo. banc 2016). Standing requires a party to “have a personal stake arising from a threatened or actual injury.” Schweich v. Nixon, 408 S.W.3d 769, 774 (Mo. banc 2013) (internal quotation omitted). The plaintiff bears the burden of proof to establish standing. Id.

This Court reviews a plaintiff's standing de novo. Airport Tech Partners, LLP v. State, 462 S.W.3d 740, 744 (Mo. banc 2015). A plaintiff must have standing for each individual claim because standing is unique to each alleged injury, and, as a result, a party may possess standing to bring some, but not all, of their claims. Weber v. St. Louis Cnty., 342 S.W.3d 318, 323 n.3 (Mo. banc 2011).

A. Park Hill School District's Standing

Park Hill alleges its status as a school district gives it standing as it has a personal stake in this litigation. Specifically, Park Hill notes it may suffer a loss of school funding as a result of this litigation's outcome. Because Park Hill's funding derives, in part, from property taxes, the lower the hotel's valuation, the less tax revenue the district is able to collect for school funding. Such a financial loss, it claims, would be detrimental to its objective of providing free public schooling. Park Hill asserts this “unique economic interest” of a school district allows it to challenge the basis or method for assessing the value of the property.

In Missouri, individual plaintiffs lack standing to challenge other taxpayers’ property tax assessments because they are not personally injured by others’ assessment calculations. Airport Tech, 462 S.W.3d at 747 (citing State ex rel. Kan. City Power & Light Co. v. McBeth, 322 S.W.3d 525, 529 (Mo. banc 2010)). This principle applies regardless of whether the plaintiff is a corporation, next-door neighbor, or a school district. McBeth, 322 S.W.3d at 530.

In McBeth, a school district and two individual plaintiffs brought a declaratory judgment action to determine if the county assessor correctly applied the appropriate tax assessment procedures to two local power plants. Id. at 528. The plaintiffs alleged a loss in tax revenue because the assessor undervalued the property. Id. Specifically, the plaintiffs claimed the assessor (1) violated a ministerial duty by failing to assess reported construction costs as the “true value in money” and apply it when calculating the taxes due, and (2) violated a ministerial duty by failing to assess the power plant as local property for the benefit of the school district. Id. at 528-29. The assessor sought writ relief in this Court after the circuit court overruled her motion to dismiss. Id. at 529. She argued the school district lacked standing to challenge the valuation or assessment. Id. This Court recognized the plaintiffs were making two separate challenges in the action for declaratory judgment, one challenging the property's past assessments and another seeking a declaration of its rights and the assessor's duties under the taxation statute. Id. at 530. This Court reaffirmed the principle that a third party is not injured by another's tax assessment, stating,

To the extent that the declaratory judgment action constitutes a challenge to past assessments, the plaintiffs lack standing. Whether the taxpaying property owner is a corporation or a next-door neighbor (and the plaintiff a school district or an individual taxpayer), the principle that a third party is not permitted to challenge another's property tax assessment applies equally.

Id. (emphasis added). When the plaintiffs sought a declaration of their rights and the assessor's duties under the applicable statutes, however, they did have standing. Id.

McBeth demonstrates a school district has a legitimate interest in protecting its funding, but it is limited to declaratory judgment actions. When a school district intervenes in the appeal of another's tax assessment, the district is not seeking a declaration of its own rights but, rather, seeking review of another's past assessment. The school district would not have standing to intervene in such an action.

Park Hill did not bring its own declaratory judgment action against Assessor, challenging section 137.115.1. Instead, Park Hill intervened when Assessor appealed the STC's decision of the hotel's property value to the circuit court. Although Park Hill has consistently argued section 137.115.1 is unconstitutional since becoming a party in this litigation, the injury it claims originates from the 2016 tax assessment of Grady's property.

While Park Hill has an interest in protecting its funding, that interest is not sufficient to grant direct standing to challenge the assessment value of a third party's property. Standing for this interest may exist when a school district brings a declaratory judgment action to determine its own rights under a statute it alleges is unconstitutional, but not when the school district is challenging the assessed value of another's property. Consequently, Park Hill does not have standing to challenge the hotel's assessment value, and its claims are dismissed.¹⁰

B. Assessor's Standing – Article I, Section 10

Assessor's first claim argues section 137.115.1 is void for vagueness, violating article I, section 10 of the Missouri Constitution, because the statute does not define the term “new construction and improvements.” Grady argues Assessor lacks standing to bring this claim because Assessor is a “political actor” who does not possess due process or equal protection rights, similar to a political subdivision.

Article I, section 10—otherwise known as the due process clause—states, “no person shall be deprived of life, liberty or property without due process of law.” Mo. Const. art. I, sec. 10 (emphasis added). The term “political subdivision” is generally used to refer to political entities such as cities, towns, and school districts. For example, the Missouri Constitution defines a political subdivision—for purposes of taxation—as, “townships, cities, towns, villages, school, road, drainage, sewer and levee districts and any other public subdivision, public corporation or public quasi-corporation having the power to tax.” Mo. Const. art. X, sec. 15.

Significantly, political subdivisions do not enjoy the same constitutional rights as Missouri citizens. Metro. St. Louis Sewer Dist. v. City of Bellefontaine Neighbors, 476 S.W.3d 913, 924 (Mo. banc 2016) (Fischer, J., concurring). A “political subdivision” is not a “person” within the meaning of section 10 and does not possess due process or equal protection rights with which to bring a claim under article I, section 10. See Bd. of Educ. of City of St. Louis v. Mo. State Bd. of Educ., 271 S.W.3d 1, 14 (Mo. banc 2008) (holding void for vagueness claims are grounded in due process rights that a city board, as a political subdivision, did not possess); Comm. for Educ. Equal. v. State, 878 S.W.2d 446, 450 n.3 (Mo. banc 1994) (noting political subdivisions are not considered persons having a constitutional right to due process or equal protection).

Until this point, this Court has not been presented with the question of whether other political actors—such as Assessor—are more akin to “persons” able to bring due process and equal protection claims or more akin to “political subdivisions” that do not possess such rights. State ex rel. Brentwood School District v. State Tax Commission, 589 S.W.2d 613 (Mo. banc 1979), is instructive to discerning whether such actors are “persons” to which due process protections apply. There, a school district tried to intervene as a party in a tax assessment case before the STC. Id. at 613. When the case reached this Court, the school district argued the STC's rule regarding intervention violated its due process right to notice and the opportunity to be heard. Id. at 615. This Court held the school district was not protected by the due process clause. Id. The Court explained “school districts, as creatures of the state established to perform governmental functions, are not persons within the protections of the due process clause and cannot charge the state with violations of due process.” Id. (emphasis added).

This same principle applies to other “creatures of the state,” such as county assessors. Section 53.010.1 grants a county the authority to elect an assessor. Without this legislative grant, the position of county assessor would not exist. Assessor acknowledges he is statutorily required to carry out governmental functions as established in section 137.115, such as making an annual list of all real and personal taxable property in the city or county to which he is elected and assessing that property's value as defined. Similar to a political subdivision, a county assessor is a “creature[ ] of the state established to perform governmental functions.” Brentwood Sch. Dist., 589 S.W.2d at 615. As such, a political actor likewise lacks due process rights to bring a claim under article I, section 10 of the Missouri Constitution.

Assessor contends he individually possesses due process rights to bring an article I, section 10 claim and does not lose that right by virtue of winning an election. Assessor is correct he would still possess such due process rights in his individual capacity, when he can show a personal stake in the outcome. Lucas v. Ashcroft, 688 S.W.3d 204, 220 (Mo. banc 2024). Assessor, however, has not brought this suit in his individual capacity, but, rather, he has proceeded through litigation in his official capacity as the Platte County assessor. When acting in his official capacity, Assessor does not possess the right to the same due process guarantees an individual citizen would possess. Brentwood Sch. Dist., 589 S.W.2d at 615. As a result, Assessor, as a political actor, does not possess due process or equal protection rights to have standing to bring a claim under article I, section 10. Accordingly, this claim is dismissed.

C. Assessor's Standing – Article I, Section 13

Assessor also contends section 137.115.1 violates article I, section 13 of the Missouri Constitution.¹¹ Section 13 expounds, “no ex post facto law, nor law impairing the obligation of contracts, or retrospective in its operation, or making any irrevocable grant of special privileges or immunities, can be enacted.” Mo. Const. art. I, sec. 13 (emphasis added). Assessor claims, because section 137.115.1 allows Grady to deduct the cost of new construction and improvements from the value of the hotel, the provision gives him an irrevocable special privilege that does not apply to similar properties not within airport boundaries.

As previously noted, political actors do not enjoy the same constitutional protections as Missouri citizens. See Metro. St. Louis Sewer Dist., 476 S.W.3d at 924. This is especially true when the constitutional provision at issue was enacted to protect Missouri citizens rather than the state or its officials. Mo. Mun. League v. State, 489 S.W.3d 765, 768 (Mo. banc 2016); Savannah R-III Sch. Dist. v. Pub. Sch. Ret. Sys. of Mo., 950 S.W.2d 854, 858 (Mo. banc 1997).

For example, in Missouri Municipal League, the Missouri Municipal League, the city of Springfield, and an individual plaintiff claimed a statutory provision violated the retrospective clause in article I, section 13 of the Missouri Constitution. Mo. Mun. League, 489 S.W.3d at 767. The circuit court dismissed the claim, finding Springfield and the Missouri Municipal League lacked standing. Id. at 768. On appeal, this Court noted, while a plaintiff may meet general standing criteria, this does not mean the plaintiff has a recognized claim under article I, section 13. Id. This Court held, “Our constitutional prohibition against laws retrospective in operation is located in our citizen bill of rights.” Id. Due to the location of this clause, the provision was intended to protect citizens, not the state. Id. Ultimately, this Court dismissed Springfield, as a state entity, because it failed to state a permissible claim. Id.

Both the retrospective law clause and the special privilege and immunity clause are in article I, section 13 of our citizen bill of rights. This bill of rights was established to protect citizens, not state or political actors. Mo. Mun. League, 489 S.W.3d at 768. Accordingly, Assessor does not have standing to bring this claim under article I, section 13, and this claim is dismissed.

D. Assessor's Standing – Article X Claims

Assessor brings two additional article X claims, arguing section 137.115.1 violates article X, section 6 by creating an unconstitutional tax exemption and violates the uniformity clause in article X, section 3. “[A] state officer has the capacity to bring suit to enforce his powers and duties under the Missouri Constitution.” Schweich, 408 S.W.3d at 775 (alteration and internal quotation omitted). While the Assessor's duties are statutory, not constitutional, this Court has recognized standing when an Assessor challenges a statute affecting his duties. See Johnson v. Springfield Solar 1, LLC, 648 S.W.3d 101 (Mo. banc 2022) (reaching the merits of an article X, section 6 constitutional challenge brought by a county assessor who sought review after the STC's ruling); St. Charles Cnty. v. Curators of Univ. of Mo., 25 S.W.3d 159 (Mo. banc 2000) (reaching the merits of an article X, section 6 claim brought by a county assessor in a declaratory judgment action). Accordingly, Assessor has standing to bring these two article X claims.

II. Assessor's Article X Claims

Assessor challenges section 137.115.1 under article X, asserting it creates a tax exemption because Grady will be able to continually deduct new construction and improvements from the value, which will eventually reach $0. Assessor also contends section 137.115.1 treats the hotel differently than like properties near it and, as such, violates the uniformity clause.

A. Assessor's Article X, Section 6 Claim

Article X, section 6 states, “All laws exempting from taxation property other than the property enumerated in this article, shall be void.” As such, “The constitution sets out the universe of property exempt from taxation. In doing so, it clearly expresses the people's intent that only a limited number of properties may be exempted from taxation.” Springfield Solar, 648 S.W.3d at 103-04 (internal citations and quotations omitted).

To understand the duties of assessors, a brief review of their statutory responsibilities is necessary. All county assessors in the state are required to assess the “true value in money” of all real property in their respective counties. Section 137.115.1. “True value in money” is “the price that the property would bring from a willing buyer when offered for sale by a willing seller.” State ex rel. Ashby Rd. Partners, LLC v. State Tax Comm'n, 297 S.W.3d 80, 82 n.2 (Mo. banc 2009) (alteration and internal quotation omitted). This price is otherwise known as the property's fair market value on the valuation date. Id.

Section 137.115.1 guides the process by which a county assessor determines the “true value in money” of commercial properties that lie on or within airport boundaries. It states, in relevant part:

The true value in money of any possessory interest in real property in subclass (3), where such real property is on or lies within the ultimate airport boundary as shown by a federal airport layout plan, as defined by 14 CFR 151.5, of a commercial airport having a FAR Part 139 certification and owned by a political subdivision, shall be the otherwise applicable true value in money of any such possessory interest in real property, less the total dollar amount of costs paid by a party, other than the political subdivision, towards any new construction or improvements on such real property completed after January 1, 2008, and which are included in the above-mentioned possessory interest, regardless of the year in which such costs were incurred or whether such costs were considered in any prior year.

Section 137.115.1 (emphasis added).

Section 137.115.1 requires Assessor to reduce the hotel's value by new construction and improvements made after January 1, 2008, “regardless of the year in which such costs were incurred or whether such costs were considered in any prior year.” Because of this continued reduction, Assessor claims the statute creates a tax exemption. In other words, Assessor argues, if Grady continues to improve the property, Grady would be able to continually reduce the value of the property by such improvements until it reaches a value of $0.

Section 137.115.1's process does not lead to a tax exemption. A tax exemption is “freedom from a duty, liability, or other requirement; an exception or an amount allowed as a deduction from adjusted gross income, used to determine taxable income.” Airport Tech Partners, 462 S.W.3d at 743 n.3 (alteration and internal quotations omitted). Section 137.115.1 does not grant Grady freedom from tax liability.

Generally, property is assessed at its “true value in money,” which is the property's fair market value on the valuation date. Ashby Rd. Partners, 297 S.W.3d at 82 n.2. Section 137.115.1 redefines the concept of “true value in money” for certain properties by requiring assessors to deduct specified construction or improvement costs from the “otherwise applicable true value in money.” Assessor's argument that this valuation formula creates an unconstitutional tax “exemption” is premised on a speculative and unsupported assumption that investments in new construction and improvements will never result in any increase in the property's fair market value. Indeed, the facts of this case belie Assessor's argument, as the circuit court affirmed the STC's decision and order valuing the hotel at $6,139,505. A $6,139,505 assessment does not result in a tax exemption. Assessor, therefore, cannot demonstrate section 137.115.1 is unconstitutional. Section 137.115.1 is not an unconstitutional tax exemption because it affects only “how the true value in money is determined for the purpose of property tax assessment.” Airport Tech Partners, 462 S.W.3d at 743 n.3.

B. Assessor's Article X, Section 3 Claim

Next, Assessor argues section 137.115.1 violates the uniformity clause in article X, section 3 of the Missouri Constitution. He contends the hotel is not being taxed uniformly as like properties in the same subclass. Article X, section 3 states, in relevant part, that taxes “shall be uniform upon the same class or subclass of subjects.” The uniformity clause requires taxes to be: “(1) uniform; (2) upon the same class or subclass of subjects; (3) within the territorial limits; (4) of the authority levying the tax.” Armstrong-Trotwood, 516 S.W.3d at 835-36 (internal quotation omitted). Article X, section 3 also provides, “the methods of determining the value of property for taxation shall be fixed by law.”

Previous interpretation of the uniformity clause shows the tax rate for the same subclass of property must be uniform, but the property values and valuation methods need not be uniform. Armstrong-Trotwood, 516 S.W.3d at 836. As such, the uniformity clause “does not apply to valuations, nor does it impose any obligations or limitations on authorities responsible for valuing or assessing property. Instead, section 3 specifically addresses value in a later provision and authorizes laws to prescribe the methods of determining the value of property for taxation.” Id. (emphasis and internal quotations omitted).

Section 137.115.1 prescribes by law the method by which Assessor is required to value the hotel. Because the hotel sits within airport property boundaries, Assessor is required to deduct new construction and improvements from the overall value to obtain the “true value in money” for the property tax assessment. Section 137.115.1. Article X, section 3 does not require Assessor to apply this same valuation method to other properties because the valuation methods are prescribed by law. The general assembly determined section 137.115.1 was the method by which Assessor should value property within airport property boundaries. As such, there is no violation of section 3, and Assessor's claim fails.¹²

Accordingly, section 137.115.1 does not create an unconstitutional tax exemption in violation of article X, section 6 nor does it violate the uniformity clause of article X, section 3 of the Missouri Constitution.

Conclusion

The circuit court's judgment is affirmed.

FOOTNOTES

1.   Unless otherwise noted, all statutory citations are to RSMo 2016.

2.   For clarity, this opinion refers to Grady's possessory ownership interest in improvements to the land as “the hotel” or “the property.”

3.   See also State ex rel. Thompson v. Osage Outdoor Advert., Inc., 674 S.W.2d 81, 84 (Mo. App. 1984) (holding this Court's cases have recognized improvements to land are real property for taxation purposes).

4.   The hearing officer declined to address the constitutional validity of section 137.115.1, finding it beyond the authority of an administrative agency.

5.   This method of valuation, called the bonus value method, does not apply to the property, Cox v. Grady Hotel Investments, LLC, 605 S.W.3d 575, 585 (Mo. App. 2020), and is not discussed in this opinion.

6.   The entire STC also declined to address the constitutional validity of section 137.115.1, determining it was beyond the authority of an administrative agency.

7.   Grady originally filed his appeal in this Court, but it was transferred to the court of appeals.

8.   The court of appeals evaluated the plain language of the sale contract between Grady, Host Hotels & Resorts, L.P., and City to determine the parties’ intent was for Grady to own the improvements, not merely to have a leasehold interest.

9.   Assessor and Park Hill both raised constitutional challenges to section 137.115.1 in the circuit court; however, the court of appeals determined the argument was moot.

10.   Moreover, property values in Park Hill's district are subject to increase or decrease based on external conditions. Allowing Park Hill to maintain standing based on this rationale would provide grounds for every school district across the state to challenge the property assessment of every third-party property that decreases in value by claiming any decrease in property tax would lower school funding. This Court has clearly rejected this basis of standing. Airport Tech, 462 S.W.3d at 747 (citing McBeth, 322 S.W.3d at 529).

11.   Assessor also asserts section 137.115.1 is a special law in violation of article III, section 40(28). He claims the language of article III, section 40(28) “practically mirrors the language of the prohibition contained in article I, section 13.” Article III, section 40(28) prevents the general assembly from passing any local or special law that grants “to any corporation, association or individual any special or exclusive right, privilege or immunity[.]” Mo. Const. art III, sec. 40(28).This argument, however, is not preserved. To raise and properly preserve a constitutional challenge, a party must “raise the constitutional question at the first available opportunity.” Fowler v. Mo. Sheriffs’ Ret. Sys., 623 S.W.3d 578, 582 (Mo. banc 2021) (internal quotation omitted). Assessor first raised his article III claim in his reply brief at the circuit court and acknowledged this failure during oral argument before this Court. Assessor did not explain how this claim is preserved for this Court's review. As such, the argument is unreviewable as unpreserved.

12.   Assessor compares the hotel to other competing hotels located within a five mile radius of KCI. He argues there is no reasonable basis to distinguish Grady's property from these other hotels. Because there is no uniformity requirement for assessment methods, this Court does not address the issue more than to note that the competitors’ properties do not sit within airport boundaries, and that alone is likely a reasonable basis to treat the properties differently.

Mary R. Russell, Judge

All concur.