McHenry Solar, LLC v. Hampton

Syllabus

The plaintiff appealed from the trial court's judgment denying its motion for summary judgment in its underlying tax appeal against the defendant on its claim that it was entitled to judgment as a matter of law that certain personal property that it used to generate electricity was exempt from taxation pursuant to statute (§ 12-81 (76)). The plaintiff claimed that the court incorrectly concluded that it was not entitled to the exemption because the generation of electricity is not manufacturing within the meaning of § 12-81 (76). Held: The trial court properly denied the plaintiff's motion for summary judgment, as, considering the legislative history of the statute and the construction of the statutory scheme as a whole, the generation of electricity is not manufacturing within the meaning of § 12-81 (76) and, thus, legislative intent renders businesses engaged in the generation of electricity ineligible for the manufacturing exemption from the property tax. Argued June 3—officially released September 23, 2025