Pinellas County purchased property in neighboring Pasco County and was charged ad valorem taxes by the Pasco County Property Appraiser. Pinellas County sued the Property Appraiser, arguing that it is not subject to such taxes on the basis of sovereign immunity. Pasco County argued, however, that Pinellas County’s immunity from taxation does not extend into Pasco County. The trial court ruled in favor of Pinellas County. On appeal, the Second District Court of Appeal reversed the trial court decision, and this appeal followed. The Second DCA certified a question of great public importance to this Court.

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