A & P RANCH LTD v. COCHISE COUNTY

IN THE
SUPREME COURT OF THE STATE OF ARIZONA

A & P RANCH LTD, ET AL.,
Plaintiffs/Appellees,

v.

COCHISE COUNTY, ET AL.,
Defendants/Appellants,

ARIZONA DEPARTMENT OF REVENUE,
Defendant-Intervenor/Appellant.

No. CV-25-0217-PR
Filed July 24, 2026

Appeal from the Arizona Tax Court
The Honorable Erik Thorson, Judge
No. TX2022-000423
AFFIRMED

Opinion of the Court of Appeals, Division One
260 Ariz. 491 (App. 2025)
VACATED

COUNSEL:

Kristin K. Mayes, Arizona Attorney General, Kimberly J. Cygan, Assistant
Attorney General, Phoenix, Attorneys for Arizona Department of Revenue

Lori A. Zucco, Cochise County Attorney, Dylan Hendel, Civil Deputy
County Attorney, Bisbee; and James M. Susa (argued), Cindy K. Schmidt,
DeConcini McDonald Yetwin & Lacy, P.C., Tucson, Attorneys for Cochise
County

Paul J. Mooney (argued), Paul Moore, Mooney, Wright, Moore & Wilhoit,
PLLC, Scottsdale, Attorneys for A & P Ranch LTD., et al.
 A & P RANCH LTD V. COCHISE COUNTY/ADOR
Opinion of the Court

JUSTICE CRUZ authored the Opinion of the Court, in which CHIEF
JUSTICE TIMMER, VICE CHIEF JUSTICE LOPEZ and JUSTICES BOLICK,
BEENE, MONTGOMERY, and KING joined.

JUSTICE CRUZ, Opinion of the Court:

¶1 We are asked to determine: (1) whether Arizona’s
agricultural-property tax statutes require permanent crops, such as orchard
trees and vineyard vines, to be valued using standard appraisal methods
and techniques when no statute prescribes a specific valuation method for
those crops; and (2) whether the court of appeals erred in holding that the
valuation method prescribed in A.R.S. § 42-13101 for “land used for
agricultural purposes” applies not only to the land itself but also to
permanent crops growing on the land.

¶2 In essence, both issues concern whether Arizona’s
agricultural-property tax statutes prescribe a valuation method for
permanent crops or whether those crops must instead be valued at full cash
value using standard appraisal methods and techniques. We conclude that
permanent crops qualifying as agricultural property under A.R.S.
§ 42-12151 are valued under the income approach prescribed by § 42-13101
and may not be separately valued using standard appraisal methods and
techniques under A.R.S. § 42-11001(6).

BACKGROUND

¶3 A & P Ranch Ltd. and other entities (collectively, “Plaintiffs”)
each own separate agricultural property in Cochise County (“County”). A
county assessor annually determines the classification, valuation, and full
cash value of all taxable property within the county. A.R.S. § 42-13051.

¶4 For tax year 2023, the County Assessor valued Plaintiffs’
agricultural properties using the methodology set forth in the Arizona
Department of Revenue’s Agricultural Property Manual (“Manual”). The
assessor valued Plaintiffs’ land at $1,800 per acre under § 42-13101. The
assessor then separately valued the orchard trees at $12,000 per acre and
the vineyard vines at $8,000 per acre using standard appraisal methods and

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Opinion of the Court

techniques to determine market value. The assessor added those values
together to determine the full cash value of each property.

¶5 Section 42-13101 prescribes the valuation method for
agricultural land. It requires qualifying agricultural land to be valued
exclusively under the income approach, using the capitalized average
annual net cash rental value of comparable agricultural property, without
regard to urban or market influences. § 42-13101.

¶6 Plaintiffs filed suit challenging the 2023 valuation of their
agricultural properties. They alleged the valuations were excessive and
contrary to law because orchard trees and vineyard vines qualify as
agricultural property under A.R.S. §§ 42-12151 and -12152 and, therefore,
must be valued under both A.R.S. §§ 42-12002(1) and -13101, not under the
latter alone. Plaintiffs requested that the tax court correct the valuations by
applying the statutory valuation method. The Department of Revenue
(“Department”) moved to intervene, and the court granted the motion. The
parties then filed cross-motions for summary judgment.

¶7 Plaintiffs argued that separately valuing the orchard trees and
vineyard vines relied on market influences and violated § 42-13101. The
County and the Department disagreed, asserting that permanent crops are
improvements to agricultural land and, therefore, may be valued
separately. The County argued that orchard trees and vineyard vines are
distinct from the underlying land and possess independent value. It further
contended that Plaintiffs misread § 42-13101 by construing the statute’s
reference to “land” to include permanent crops. The Department similarly
argued that §§ 42-13101 and -13102 prescribe a valuation method for
agricultural land, but not for improvements situated on that land.

¶8 The tax court concluded that § 42-13101 governs the valuation
of agricultural land and that the statute does not distinguish between
“land” and “permanent crops.” The court, therefore, held that permanent
crops must be valued together with the underlying land under § 42-13101.
The court also found that no statute expressly classifies orchard trees or
vineyard vines as improvements to land. Accordingly, the court granted
summary judgment for Plaintiffs and entered judgment against the County
and the Department.

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Opinion of the Court

¶9 The County and the Department appealed. The court of
appeals affirmed, holding that permanent crops, including orchard trees
and vineyard vines, must be valued together with the underlying land
under the income approach prescribed by § 42-13101. A & P Ranch Ltd. v.
Cochise County, 260 Ariz. 491, 493 ¶ 1 (App. 2025). The County and the
Department petitioned for review.

¶10 We granted review to clarify the interaction between
Arizona’s agricultural-property classification statutes and valuation
provisions, an issue of statewide importance concerning the uniform
assessment of agricultural property. We have jurisdiction pursuant to
article 6, section 5(3) of the Arizona Constitution.

DISCUSSION

¶11 We review the tax court’s grant of summary judgment de
novo. Wilderness World, Inc. v. Dep’t of Revenue, 182 Ariz. 196, 198 (1995).
We likewise review questions of statutory interpretation de novo. SolarCity
Corp. v. Ariz. Dep’t of Revenue, 243 Ariz. 477, 480 ¶ 8 (2018).

¶12 “We review issues construing statutes and rules de novo.”
Ariz. Pub. Integrity All. v. Fontes, 250 Ariz. 58, 61 ¶ 8 (2020). And “we begin
with the text” when construing statutes. Franklin v. CSAA Gen. Ins. Co.,
255 Ariz. 409, 411 ¶ 8 (2023). We interpret statutes “according to the plain
meaning of the words in their broader statutory context, unless the
[L]egislature directs us to do otherwise.” In re Drummond, 257 Ariz. 15, 21
¶ 19 (2024) (quoting S. Ariz. Home Builders Ass’n v. Town of Marana, 254 Ariz.
281, 286 ¶ 31 (2023)). But statutory language cannot be read in isolation.
Rather, we interpret statutes in their broader statutory context and in
conjunction with related statutes addressing the same subject matter. In re
Drummond, 257 Ariz. at 21 ¶ 19; Stambaugh v. Killian, 242 Ariz. 508, 509 ¶ 7
(2017). If ambiguity remains after applying the ordinary tools of statutory
construction, we resolve that ambiguity in the taxpayer’s favor. San Diego
Gas & Elec. Co. v. Ariz. Dep’t of Revenue, 259 Ariz. 105, 108 ¶ 11 (2025) (“In
the event of ambiguity, we construe statutes in favor of the taxpayer.”).
Arizona’s property-tax system consists of four components: classification,
valuation, assessment ratio, and tax rate. Aileen H. Char Life Int. v. Maricopa
County, 208 Ariz. 286, 291 ¶ 8 (2004). The Legislature determines a
property’s classification and valuation methodology, the assessor applies
that methodology, the applicable assessment ratio is applied to the

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Opinion of the Court

classified value, and the resulting assessed value is multiplied by the
applicable tax rate to determine the taxes owed. Id.

¶13 This case concerns the interaction between Arizona’s
agricultural-property classification statutes and its agricultural-property
valuation statutes. Specifically, we must determine whether permanent
crops that qualify as agricultural property under § 42-12151 are valued
under the income approach prescribed by § 42-13101 or whether they may
instead be separately valued at market value under § 42-11001(6).
Resolution of that question requires us to read the relevant statutes as an
integrated whole.

¶14 “In construing a specific provision, we look to the statute as a
whole and we may also consider statutes that are in pari materia—of the
same subject or general purpose—for guidance and to give effect to all of
the provisions involved.” State Farm Mut. Auto. Ins. Co. v. Orlando, 259 Ariz.
531, 534 ¶ 10 (2025) (quoting Stambaugh, 242 Ariz. at 509 ¶ 7). Statutes
addressing the same subject are construed as though they constitute one
law. State ex rel. Dep’t of Econ. Sec. v. Hayden, 210 Ariz. 522, 523 ¶ 7 (2005).
This principle is a fundamental tool of statutory construction. Orlando,
259 Ariz. at 536 ¶ 24. It is particularly applicable here because §§ 42-12151
and -13101 address complementary aspects of Arizona’s
agricultural-property tax scheme.

¶15 Section 42-12151 identifies the property that qualifies for
agricultural classification. As relevant here, agricultural real property
includes “[c]ropland in the aggregate of at least twenty gross acres” and
“[a]n aggregate ten or more gross acres of permanent crops.”
§ 42-12151(1)–(2). These provisions determine which property receives the
benefit of agricultural classification.

¶16 Section 42-13101 prescribes how an assessor values qualifying
agricultural property. It provides that “[l]and that is used for agricultural
purposes shall be valued using only the income approach to value without
any allowance for urban or market influences.” § 42-13101(A). The statute
further directs assessors to determine agricultural income by capitalizing
the property’s average annual net cash rental. § 42-13101(B).

¶17 Read together, §§ 42-12151 and -13101 establish a unified
statutory scheme governing both the classification of agricultural property

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Opinion of the Court

and the exclusive method for valuing that property. Section 42-12151
identifies the property qualifying for agricultural treatment, while
§ 42-13101 prescribes the valuation methodology applicable to that
qualifying property. Under § 42-12151(2), agricultural real property may
consist of land containing permanent crops. The statute qualifies such
property by reference to its “aggregate ten or more gross acres,” confirming
that the Legislature treated permanent crops as attributes of qualifying
cropland rather than as improvements separate from the land. See
§ 42-12151(2). Although § 42-12151 refers to land containing permanent
crops, the income approach prescribed by § 42-13101 is based on the
agricultural income produced from that land. The permanent trees and
vines serve as the means of producing the crop; it is the harvested nuts,
fruits, or grapes—not the trees and vines themselves—that generate the net
cash rental income used in the statutory valuation. Nothing in the statutory
framework suggests that the Legislature intended to remove permanent
crops from that unified valuation scheme and to separately value them as
improvements.

¶18 The Legislature’s choice of language reinforces that
conclusion. Several subsections of § 42-12151 expressly refer to “land and
improvements.” See § 42-12151(4)–(12). By contrast, subsections (1)
and (2), governing cropland and permanent crops, contain no such
language. When the Legislature uses different language within the same
statutory scheme, we presume it intended different meanings. Comm. for
Pres. of Established Neighborhoods v. Riffel, 213 Ariz. 247, 249–50 ¶ 8
(App. 2006). We therefore decline to insert language the Legislature
omitted. See City of Phoenix v. Donofrio, 99 Ariz. 130, 133 (1965) (“A
fundamental rule of statutory construction is that courts will not read into
a statute something which is not within the manifest intention of the
[L]egislature as gathered from the statute itself.”).

¶19 Accordingly, when § 42-13101 refers to “[l]and that is used for
agricultural purposes,” that phrase encompasses agricultural property
qualifying under § 42-12151(2) by virtue of its permanent crops. In other
words, it is the presence of permanent crops that provides the defining
feature that qualifies land as “agricultural property.” The land and the
crops then serve as the taxable unit. The Legislature did not separately
classify permanent crops as improvements for purposes of
agricultural-property valuation.

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Opinion of the Court

¶20 The statutory text alone resolves this case. The Legislature’s
purpose confirms that reading. Arizona’s property-tax scheme values
property according to its statutorily prescribed current use. See Mesquite
Power, LLC v. Ariz. Dep’t of Revenue, 258 Ariz. 1, 10 ¶ 39 (2024) (recognizing
that valuation under Arizona’s property-tax statutes reflects the property’s
current use); Golder v. Dep’t of Revenue, 123 Ariz. 260, 265–66 (1979) (holding
that agricultural property is valued according to its current agricultural use
rather than its highest and best use). Arizona courts have long recognized
that this approach protects agricultural production from the tax burdens
that would result if farmland were valued according to surrounding
development or speculative market forces. See Maricopa County v. State, 187 Ariz. 275, 281 (App. 1996); Golder, 123 Ariz. at 265.

¶21 Although orchard trees and vineyard vines are physically
distinguishable from the underlying soil, the Legislature chose to treat
qualifying agricultural property as a single unit for valuation under
§§ 42-12151 and -13101. The statutory scheme, therefore, does not permit
assessors to separate permanent crops from the qualifying agricultural
property and value them under a different methodology.

¶22 Section 42-13101 implements that legislative policy by
requiring agricultural property to be valued “using only the income
approach to value without any allowance for urban or market influences.”
We give effect to every provision of the statutory scheme and avoid
constructions rendering statutory language superfluous. Nicaise v.
Sundaram, 245 Ariz. 566, 568 ¶ 11 (2019). Permitting assessors to assign a
separate market value to permanent crops would reintroduce precisely the
market influences that § 42-13101 directs assessors to disregard. Rather
than valuing agricultural property according to its productive agricultural
use, the assessor would supplement the Legislature’s prescribed income
methodology with a second valuation method based upon market value.
That approach is inconsistent with the text and undermines the purpose of
Arizona’s agricultural-property valuation statutes.

¶23 Section 42-13101(B) requires assessors to determine value by
capitalizing the property’s average annual net cash rental using comparable
agricultural property. Comparable orchards and vineyards necessarily
command rental values reflecting the productive characteristics created by
permanent crops. Thus, the Legislature’s prescribed methodology captures
the economic contribution of those crops through the property’s

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Opinion of the Court

income-producing capacity. Because permanent crops qualify the property
for agricultural treatment under § 42-12151, and § 42-13101 prescribes the
exclusive valuation methodology for that property, assessors may not
separate one component of qualifying agricultural property and value it
under a different methodology.

¶24 By first valuing qualifying agricultural property using the
income approach and then separately assigning market value to the orchard
trees or vineyard vines, the assessor effectively subjects the same
productive agricultural value to two separate and cumulative valuation
methodologies. That result is inconsistent with the Legislature’s decision
to prescribe a single income-based valuation methodology for qualifying
agricultural property and with its express directive that Title 42 “shall not
be construed to require or permit double taxation.” A.R.S. § 42-11003. We
decline to construe the valuation statutes in a manner that produces the
very double taxation the Legislature has expressly forbidden.

¶25 Section 42-11001(6) does not compel a different result. That
statute provides that full cash value is synonymous with market value only
when no statutory valuation method has been prescribed. Here, however,
the Legislature has prescribed a valuation method. Once property qualifies
for agricultural valuation under § 42-12151, then § 42-13101 governs how
that property is valued. Therefore, resorting to a separate market valuation
of permanent crops under § 42-11001(6) is neither necessary nor authorized.

¶26 Nor does our interpretation render the general valuation
statutes superfluous. Property that does not qualify for agricultural
valuation remains subject to valuation under the general provisions of
Title 42, including § 42-11001(6). The Legislature simply established a
different valuation methodology for qualifying agricultural property. Had
it intended permanent crops to be removed from that unified valuation
system and separately valued according to market value, it would have said
so expressly.

¶27 The Department nevertheless argues that permanent crops
constitute improvements that may be separately valued under its Manual.
This dispute arises from that administrative classification. The Manual
instructs assessors that permanent crops are improvements to land and
should be valued separately from the land using market-based
considerations.

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Opinion of the Court

¶28 The Manual’s approach, however, conflicts with the statutory
framework. Sections 42-12151 and -13101 neither classify permanent crops
as separately taxable improvements nor authorize assessors to employ a
second, market-based valuation methodology for those crops. Instead, the
Legislature prescribed one valuation method for qualifying agricultural
property and directed that it be applied “without any allowance for urban
or market influences.”

¶29 The Department undoubtedly possesses the authority to
prepare manuals and guidance implementing Arizona’s property-tax
statutes. See A.R.S. § 42-11054(A)(2) (directing the Department to
“[p]repare and maintain manuals and other necessary guidelines, consistent
with this section, reflecting the standard methods and techniques to
perpetuate a current inventory of taxable property and the valuation of that
property” (emphasis added)). But implementation differs from alteration.
The Legislature authorized the Department to administer the statutory
valuation scheme—not to redefine qualifying agricultural property or
adopt a different valuation methodology than the one the Legislature
prescribed. Administrative guidance may assist in applying the statutes,
but it cannot revise or supersede them. See A.R.S. § 42-2080(A); Maricopa
County v. Viola, 251 Ariz. 276, 279 ¶ 11 (App. 2021).

¶30 Nor may an administrative manual expand the taxing
authority granted by statute. Taxing authority “must be made clearly to
appear[,] and doubts, if any, as to the power sought to be exercised must be
resolved against” the taxing authority. City of Phoenix v. Ariz. Sash, Door &
Glass Co., 80 Ariz. 100, 102 (1956). Consistent with that principle, we have
recognized that when interpreting a political subdivision’s authority to
impose a tax, doubts concerning the scope of that authority are resolved
against the taxing authority. Vangilder v. Ariz. Dep’t of Revenue, 252 Ariz.
481, 488 ¶ 26 (2022). Nothing in Arizona’s agricultural-property statutes
clearly authorize the separate market valuation of permanent crops.

¶31 The Manual directs assessors to substitute market-based
judgments for the Legislature’s prescribed income methodology. To the
extent the Manual requires assessors to assign separate market values to
permanent crops in addition to valuing qualifying agricultural property
under § 42-13101, it departs from the statutory framework established by
the Legislature and is void.

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Opinion of the Court

¶32 Any practical difficulty in applying the Legislature’s chosen
valuation methodology is a matter for the Legislature—not the
Department—to address. Courts, likewise, may not rewrite the statutory
framework in the name of administrative convenience. Our task is to apply
the valuation system that the Legislature enacted.

¶33 We, therefore, conclude that land with permanent crops
qualifying as agricultural property under § 42-12151 must be valued under
the income approach prescribed by § 42-13101. Because the Legislature has
prescribed that valuation methodology, county assessors may not
separately value permanent crops using standard appraisal methods and
techniques under § 42-11001(6). Accordingly, the Manual is unenforceable
to the extent it classifies permanent crops as separately market-valued
improvements or otherwise conflicts with the governing statutes.

CONCLUSION

¶34 Land with permanent crops that qualifies as agricultural
property under § 42-12151 is valued under the income approach prescribed
by § 42-13101. Read together, §§ 42-12151 and -13101 establish a unified
framework governing both the classification of agricultural property and
the exclusive method for valuing that property. Because the Legislature has
prescribed a specific valuation methodology, county assessors may not
separately value permanent crops using standard appraisal methods and
techniques under § 42-11001(6).

¶35 The Manual cannot alter that statutory framework. Although
the Department may issue guidance to assist in implementing Arizona’s
property-tax statutes, it may not adopt a valuation methodology
inconsistent with the one the Legislature enacted. To the extent the Manual
classifies permanent crops as separately market-valued improvements, it
conflicts with Arizona’s agricultural-property tax statutes and is not
controlling.

¶36 Although we agree with the court of appeals’ ultimate
disposition, we vacate its opinion to replace its reasoning with our own.
We affirm the tax court’s judgment.

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Opinion of the Court

ATTORNEY FEES

¶37 Plaintiffs request an award of attorney fees and costs under
A.R.S. § 12-348(B). Although the County asked this Court to reverse the
court of appeals’ award of attorney fees, neither the County nor the
Department opposed Plaintiffs’ request for attorney fees incurred in this
Court. Section 12-348(B)(1) authorizes a court to award reasonable attorney
fees and other expenses to a prevailing party in an action challenging the
assessment, collection, or refund of taxes. Because Plaintiffs prevail in this
tax appeal, we award them their reasonable attorney fees and costs upon
compliance with Arizona Rule of Civil Appellate Procedure 21.

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