In the last few years, Downingtown Area School District in Chester County has found itself at the center of several important decisions in the realm of Pennsylvania tax assessment law.

The first and most significant of these was Downingtown Area School District v. Chester County Board of Assessment Appeals, 131 A.3d 152 (Pa. 2006), known as Downingtown I, where the Pennsylvania Supreme Court held that a taxpayer may prove nonuniformity by presenting evidence of the assessment-to-value ratio of several similar properties in the same neighborhood as the subject property. The court also appeared to invalidate a provision of the now-replaced Second Class A and Third Class County Assessments Law, which required appeals boards to apply the county’s established predetermined ratio—rather than the common level ratio published by the State Tax Equalization Board—to the property’s market value, and to apply the CLR only if it varied by the EPR by more than 15%. (Note, however, that both the General County Assessment Law and the Consolidated County Assessment Law still contain identical provisions.)