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October 30, 2025

Court Upholds HB-242: What the Ruling Means for Property Owners

Delaware Court of Chancery ruled in favor of defendants on October 30, 2025, upholding House Bill 242 as constitutional. All six challenges were rejected. Learn what this means for your property taxes.

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On October 30, 2025, Vice Chancellor Lori Will of the Delaware Court of Chancery issued a 58-page opinion upholding House Bill 242 as constitutional. The court rejected all six challenges brought by property owner associations, allowing New Castle County to implement the dual tax rate system for the 2025-2026 school year.
⚖️ The Court's Decision

Vice Chancellor Lori Will entered judgment for the defendants on all counts, finding that House Bill 242 and its implementation do not violate the United States Constitution, the Delaware Constitution, or state statutes. The 58-page opinion systematically addressed and rejected each of the six challenges raised by plaintiff property owner associations.

📋 Key Findings from the Court

The court's ruling addressed six major constitutional and statutory challenges:

1
Count I - Uniformity Clause: Legislature has the right to classify property for taxation purposes. The distinction between residential and non-residential properties is reasonable and constitutional.
2
Count II - Retroactive Taxation: Delaware's prohibition on retroactive taxation applies only to personal income taxes, not property taxes. HB242 levies an ad valorem property tax.
3
Count III - Referendum Requirement: HB242 functions as a specific, time-limited exception to the general referendum requirement through its 'notwithstanding' clause.
4
Count IV - Fair Market Value: Property assessments remain valid as of the July 1, 2024 base year. Events after that date are legally irrelevant to assessment validity.
5
Count V - Revenue Neutrality: School boards complied with HB242's requirement based on data available when they set tax rates. The statute required a projection, not perfect accuracy.
6
Count VI - Due Process: Post-deprivation remedies, including the County's administrative policy and judicial review, provide adequate due process for property owners.
🏠 What This Means for Property Owners

The court's decision has immediate and concrete implications for all New Castle County property owners:

HB-242 Is Valid

The dual tax rate system distinguishing between residential and non-residential properties is constitutional and will be implemented.

Action: The court has validated the use of different school tax rates for residential versus non-residential properties for the 2025-2026 tax year.

📬

Tax Bills Will Be Issued

New Castle County can now proceed with issuing supplemental school tax bills that reflect the dual tax rate system.

Action: Property owners should expect to receive supplemental tax bills in the coming weeks that implement the school district rates established under HB-242.

🔄

Classification Corrections Allowed

The County may correct property classification errors, and affected property owners will have opportunities to challenge those corrections.

Action: If your property classification is corrected, you'll be notified and have the right to appeal through established administrative procedures.

📅

One-Year Law Only

This ruling applies only to the 2025-2026 tax year, as HB-242 is a temporary, one-year measure.

Action: The legislature may consider permanent tax structure changes in future sessions.

⏭️ What Happens Next

Here's what property owners can expect in the coming days and weeks:

Court Decision Issued

October 30, 2025

County Begins Processing Tax Bills

Shortly After Ruling

Supplemental School Tax Bills Mailed

Coming Weeks

Property Owners Can Review and Appeal Classifications

After Bill Receipt

Potential Consideration of Permanent Tax Structure

2026 Legislative Session
📚 Additional Resources

Explore these resources to learn more about the court decision and your tax situation:

  • Complete court ruling summary with analysis of all six counts
  • Full 58-page court opinion (PDF) from Delaware Courts
  • Original case background and legal arguments
  • House Bill 242 full text and explanation
  • School district tax rates for all five districts
  • Property classification appeal procedures

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