Property owners challenge Maryland law that blocks courts from stopping unconstitutional tax assessments

On July 28, 2025, Justly Prudent filed a complex constitutional lawsuit in Prince George's County Circuit Court on behalf of property owners who face financial ruin from a discriminatory tax assessment—and who are blocked by Maryland law from asking any court to stop it.

The lawsuit centers on The Oxford, a 187-unit luxury apartment complex in Oxon Hill, Maryland, that the owners transformed from a vacant, dilapidated office building into a thriving residential community. After investing millions in the redevelopment, the owners now face a tax assessment so inflated and arbitrary that it threatens to force them into bankruptcy.

The Maryland State Department of Assessments and Taxation increased the property's assessed value from $49 million to $70 million—a shocking 43% jump that far exceeds the statewide average increase of 17.6% for commercial properties. According to the complaint, SDAT achieved this figure by improperly treating a 2020 financing arrangement as if it were an actual sale of the property, a methodology the agency itself rejected when it assessed the same property just three years earlier.

The financial impact of SDAT's decision is staggering. The reassessment saddles the owners with more than $1 million in additional taxes over the next three years. Because the owners personally guaranteed the property's financing, both face personal bankruptcy if the assessment stands.

Under normal circumstances, property owners facing such treatment could ask a court for emergency relief while their appeal works through the administrative system. But Maryland's Tax Anti-Injunction Statute—Tax-General Section 13-505—categorically prohibits any court from issuing an injunction, declaratory judgment, or any other remedy to stop the collection of a tax. The statute makes no exception for assessments that violate constitutional rights, even if the harm is ongoing.

The lawsuit challenges this statute on multiple constitutional grounds. It argues that by stripping courts of their power to provide relief against ongoing constitutional violations, the Maryland General Assembly violated the separation of powers guaranteed by Article 8 of the Maryland Declaration of Rights. The complaint also asserts that the statute, as applied to these plaintiffs, violates the Equal Protection, Due Process, and Takings Clauses of the Fourteenth Amendment.

The complaint details how SDAT's assessment methodology discriminates against The Oxford compared to similar luxury apartment properties in Prince George's County. Despite having the ninth-lowest effective rents among comparable properties, The Oxford was assessed at the highest price per unit of any Class A apartment complex in the county. The gross rent multiplier applied to the property—15.17 times annual rent—is approximately double the industry standard range and was not applied to any other comparable property.

The administrative appeals process offers no meaningful remedy. According to the complaint, conversations with county officials confirmed that the assessment appeals system is severely backlogged, with cases taking two or more years to resolve. During that time, the owners must continue paying taxes based on the unconstitutional assessment or face collection actions.

The case raises fundamental questions about the limits of legislative power to restrict judicial authority. While Maryland has a legitimate interest in efficient tax collection, the lawsuit argues, that interest cannot justify a blanket prohibition that prevents courts from stopping constitutional violations—particularly when the administrative process is inadequate to provide timely relief.

The case is 6009 Oxon Hill Road, LLC, et al. v. State of Maryland, et al. (Case No. C-16-CV-25-004189), filed in the Circuit Court for Prince George's County, Maryland.