Friendship Manor Property Tax Case Heard by Appeals Court

May 10, 2017

The Third District Appellate Court in Illinois may decide whether Friendship Manor continues to get a property tax exemption. In 2014, Rock Island County Chief Assessor, Larry Wilson, denied the homestead exemption to the nonprofit after it had been receiving it for many years.

Michelle O'Neill reports on oral arguments in the case.


Friendship Manor's attorney, Floyd Perkins says three years ago, the continuing care retirement center received a significantly higher property tax bill than the year before. Chief Assessor, Larry Wilson, had denied the 501-c-3 organization the homestead exemption. Friendship Manor decided to ask a Rock Island County judge to rule on the denial. It lost and filed an appeal.

During oral arguments, Third District Appellate Court Justice Mary K. O'Brien questioned Perkins about why Friendship Manor didn't do what property owners usually do which is go to the Board of Review. Perkins told her boards of review usually deal with assessment challenges, not those that require interpretation of the law.

Matthew Trapp, the attorney representing Wilson, began his oral argument by saying neither the circuit court nor the appellate court have jurisdiction in the case. 

The Rock Island School District is an intervenor in the case. Its lawyer, Daniel Hardin, told the appellate court Friendship Manor is not correctly interpreting Illinois property tax law. Hardin said the purpose of exemptions is to give tax relief to individual property owners who live in the homes.

Friendship Manor's lawyer, Floyd Perkins, rebutted that argument, saying the statute does include nursing homes and assisted living centers, called "life care facilities."

Rock Island County tax records show Friendship Manor's property tax bill increased 45% from 2013 to 2014. And this is just one of three of Friendship Manor's property tax disputes.

Note: The audio for this story is from a page at called, Third District Appellate Court Oral Argument Audio 2017. You may listen to the oral arguments in the Friendship Manor v. Wilson case HERE.