Full Opinion

IN THE COURT OF APPEALS OF IOWA _______________ No. 25-0578 Filed October 7, 2026 _______________ Arconic US, LLC, Plaintiff–Appellant, v. Scott County Board of Review, Defendant–Appellee. _______________ Appeal from the Iowa District Court for Scott County, The Honorable Patrick A. McElyea, Judge. _______________ AFFIRMED _______________ Deborah M. Tharnish, Sarah K. Franklin, and Spencer Willems of Dentons Davis Brown PC, Des Moines, attorneys for appellant. John E. Lande and Benjamin J. Kenkel of Dickinson, Bradshaw, Fowler & Hagen, P.C., Des Moines, attorneys for appellee. _______________ Considered without oral argument by Chicchelly, P.J., and Buller and Sandy, JJ. Opinion by Sandy, J. 1 SANDY, Judge. Arconic US, LLC owns an aluminum rolling mill in Scott County that runs roughly a mile from end to end and straddles the boundary between Riverdale and Bettendorf. The plant covers more than five million square feet, has been built out in stages since 1948, and is assessed as two parcels that the appraisers agree function as a single economic unit. Property of that kind is hard to value. The four appraisers who testified at trial reached reconciled opinions ranging from $35,000,000 to $103,150,000. Arconic protested the 2023 assessment of $52,889,200 for the whole property, the Scott County Board of Review denied the protest, and the district court tried the appeal in equity and determined the property’s value anew at $50,102,085. Arconic now contends that the district court’s choices among the appraisers were legal errors entitled to no deference, that the court could not discount the cost approach and then sustain a cost-derived assessment, that it credited a sales comparison built on unadjusted leased fee, multitenant, and distressed sales, that it treated county-wide assessment trends as evidence of this property’s value, and that it treated the assessment as presumptively correct. On de novo review, we affirm. BACKGROUND FACTS AND PROCEEDINGS Arconic’s aluminum rolling mill and industrial manufacturing complex is located within Riverdale in Scott County, part of which lies within the Bettendorf city limits. The district court described the facility as containing 5,793,834 square feet of gross building area on a gross site area of 427.92 acres—one of the largest industrial facilities in the country. Although it operates as a single facility, the complex is divided for assessment purposes into two adjacent parcels. The larger, parcel no. 842607001 (the “Riverdale parcel”), comprises 409 acres and an assessed gross building area of 2 5,413,693 square feet; it includes most of the plant along with parking lots, storage tanks, outbuildings, storage yards, rail spurs, and two water towers. The smaller, parcel no. 842449001 (the “Bettendorf parcel”), comprises 18.9 acres and an assessed gross building area of 316,514 square feet, and includes a portion of the north part of the plant. The plant comprises three primary buildings originally constructed in 1948 and expanded in each succeeding decade, most recently in 2014. Though the property adjoins the Mississippi River, it has no barge dock infrastructure, which limits its industrial utility. John Riches, an Arconic representative, testified that the facility extends roughly a mile from end to end, contains approximately 400 craneways, operates twenty-four hours a day, and employs some 2,500 people, and that the successive additions were undertaken to meet Arconic’s particular operational requirements rather than pursuant to any unified design. The district court found that the property “is one, single industrial property and operates as such,” that its size “reduces the number of potential buyers and contributes to significant obsolescence,” and that its construction in multiple phases over several decades “creates a segmented layout and inefficiencies.” Every witness, including the assessor, testified that the property is essentially one parcel and should be valued as such. As of January 1, 2023, the Scott County Assessor valued the two parcels at a combined $52,889,200—$47,624,500 for the Riverdale parcel ($6,908,400 land and $40,716,100 improvements) and $5,264,700 for the Bettendorf parcel ($1,145,700 land and $4,119,000 improvements). In the years preceding the 2023 assessment, the property had been “locked in” to a value of $42,508,000 based on a comparable property in Ohio. For 2023, the Riverdale parcel’s land valuation rose 14 percent and its improvement 3 valuation rose 18.5 percent, for a combined increase of 17.8 percent. The Bettendorf parcel’s land valuation rose 141 percent (from $473,500) and its improvement valuation rose 151 percent (from $1,635,270). Scott County Assessor Tom McManus attributed the increases to the property’s stagnant prior valuations, post-pandemic increases in property values and construction costs, and a change in the valuation handbook his office uses. The assessor’s office values land and improvements separately by a process that, as the district court observed, “resembles the cost approach.” Four separate appraisers valued the property as follows: Appraiser Sales Cost Income Reconciled Jenkins (CBRE)— $34,760,000 $41,610,000 $35,220,000 $35,000,000 Arconic Helland (Newmark)— $40,600,000 $42,350,000 — $41,475,000 Arconic Kirchner (Dascher)— $49,825,000 $62,475,000 — $50,480,000 Board Fisher (Westrock)— $103,150,000 $179,075,000 $111,425,000 $103,150,000 Board Helland revised his cost approach during his testimony to reflect useable acres, and the district court recalculated his reconciled value accordingly. Arconic contends Helland’s own final reconciled opinion was $42,000,000. Peter Helland, who holds MAI and AI-GRS designations from the Appraisal Institute, testified that the property’s scale places it in a national rather than a regional market. He identified six comparable sales of large industrial facilities ranging from approximately 1.6 million to 6.2 million square feet—a steel mill in East Chicago, a former Ford plant in Ohio, an aircraft parts factory in Nashville, an industrial facility in Pennsylvania, an industrial business park in Georgia, and a General Motors plant in Ohio— and adjusted for age, size, condition, and location. He derived an adjusted range of $4.91 to $8.72 per square foot, selected $7.00, and determined a sales comparison value of $40,600,000. He also developed a cost approach 4 but no income approach. Chris Jenkins, who likewise holds an MAI designation, developed all three approaches. He testified that his sales comparison conclusion rested principally on the sale of the General Motors plant in Ohio. Patrick Kirchner developed sales comparison and cost approaches using eight comparable sales and valued the Riverdale parcel at $8.50 per square foot and the Bettendorf parcel at $11.00 per square foot. The county assessor, his client, instructed him to value the two parcels separately; he testified that absent that instruction he “would have valued the whole,” because the property “operates as one manufacturing plant it just happens to have two addresses and two jurisdictions.” On cross-examination, Kirchner acknowledged that his sales sheets do not identify the property rights conveyed and that he could not say whether individual sales were fee simple or leased fee. He agreed that “knowing the property rights conveyed is necessary to know whether you need to make adjustments.” Shown that a number of his sales were leased fee, he agreed that had he known at the time he “would have made an adjustment under property rights conveyed,” that he made no such adjustment, that he does not know the lease terms, and that “as we sit here today” he does not know whether he should have made the adjustment. He also made no adjustment for market conditions or time, though his sales ran from January 2018 to the January 2023 valuation date, and no adjustment for sales conditions on any property, including one sale out of bankruptcy. Sally Fisher developed all three approaches and reconciled to $103,150,000, approximately twice the assessed value. Arconic timely protested the 2023 valuation of both parcels to the Scott County Board of 5 Review. The Board denied the protests. Arconic appealed to the district court pursuant to Iowa Code section 441.38 (2023). The district court conducted a three-day bench trial in January 2025, receiving testimony from the four appraisers, Riches, and Assessor McManus. The court found that Arconic had presented competent evidence that the market value of the property differs from the value the assessor determined so that the burden shifted to the assessor under Iowa Code section 441.21(3)(b)(2). The court then found that the assessor “met their burden with respect to the Riverdale parcel and failed to meet their burden with respect to the Bettendorf parcel.” Its principal findings were: • The court disregarded Fisher’s appraisal, which was “nearly double the assessed value and was an outlier compared to the other three appraisals,” and found her testimony “unpersuasive as she explained her valuation.” There was “substantially more credible evidence supporting the other appraisals.” • The court gave no weight to the income approach. Only two appraisers developed one, and the court did “not find the income approach to be relevant in this case considering the nature of the property.” • The court gave “less weight to the cost approach due to the substantial depreciation that is required to accurately reflect the current state of the Property,” and was “concerned with the speculative nature of valuing replacement cost solely based on the Marshall Valuation Service (MVS).” • The court found “that Jenkins sales approach valuation is simply too low to be considered.” 6 • The court found that Kirchner “had the most glaring issues with his sales comparison valuation,” that “[m]any of his comps were multitenant facilities,” and that “he was uncertain about whether the sales were in fee simple or a lease fee.” It nonetheless found his $8.50 per square foot figure for the Riverdale parcel “not excessive” and “fairly consistent with the Assessor’s value,” while finding that his $11.00 per square foot figure for the Bettendorf parcel “artificially inflated” his overall conclusion. Revising his valuation to $8.50 per square foot throughout, the court observed, “yields a total valuation of $48,706,760.” • The court found that Helland “used the better comparison sales but discounted the overall value too severely,” that his $7.00 per square foot figure “does not adequately account for the land and the buildings,” and that he “discounted the land value substantially compared to the other appraisers.” • The court found that Assessor McManus “credibly testified” that his office reduced the value of unusable acres by ninety percent and took “a conservative approach to depreciation,” and that he “had a logical and consistent explanation for the increase in value”: the property’s valuation had been stagnant, post-pandemic property values rose “anywhere from 11% to 20%,” and a change in the valuation handbook raised replacement costs. The Riverdale parcel’s 18% increase, the court found, “is in line with the overall increase in property values and also reflects the stagnant valuation for the prior years,” whereas other properties “may have received 5% increases over the last 3 assessments.” 7 • As to the Bettendorf parcel, the court found that the assessor “did not have any explanation for the disparate increase between the Riverdale and Bettendorf properties,” and that there was “no compelling reason to treat these parcels differently.” Because the assessor had carried the burden on the Riverdale parcel but not the Bettendorf parcel, the court left the Riverdale valuation at $47,624,500 and applied to the Bettendorf parcel the same increases the Riverdale parcel had received—14 percent on land and 18.5 percent on improvements. Applied to the Bettendorf parcel’s prior values, that yielded land of $539,790 and improvements of $1,937,795, and a total valuation of $50,102,085. Arconic now appeals. STANDARD OF REVIEW A taxpayer dissatisfied with the disposition of its protest may appeal to the district court, which “hears the case in equity and determines anew those assessment issues previously presented to the board.” Compiano v. Bd. of Rev., 771 N.W.2d 392, 396 (Iowa 2009). Because the proceeding is in equity, our review is de novo. Id. at 395. The appeal is tried anew, and “[t]here is no presumption the assessment or valuation at issue was correct.” Id. at 396. De novo review “means we review the entire record and decide anew the issues properly preserved for appellate review,” but it “does not mean that we decide the case in a vacuum or approach it as though the trial court had never been involved.” Hora v. Hora, 5 N.W.3d 635, 645 (Iowa 2024) (cleaned up). While not bound by the district court’s findings, we give them weight and defer “especially where the credibility of witnesses is a factor in the outcome.” Id. (cleaned up). 8 That deference has a particular force in valuation disputes because courts reviewing assessment challenges “usually lack technical expertise in appraising commercial real estate, these types of cases often hinge on a factfinder’s judgment about conflicting expert witness testimony.” Nationwide Mut. Ins. v. Polk Cnty. Bd. of Rev., 983 N.W.2d 37, 38 (Iowa 2022). DISCUSSION The district court heard the four appraisers, Arconic’s representative, and the assessor, and was positioned to gauge the reliability of each. We weigh the evidence independently, but we do so mindful that the district court observed the witnesses whose competing methodologies drive the result. See Hora, 5 N.W.3d at 645. As the complainant, Arconic bore the initial burden of attacking the valuation as excessive. Iowa Code § 441.21(3)(b)(2). For assessment years beginning on or after January 1, 2018, “when the complainant offers competent evidence that the market value of the property is different than the market value determined by the assessor, the burden of proof thereafter shall be upon the officials or persons seeking to uphold such valuation to be assessed.” Id. That provision replaced the former requirement of competent evidence from at least two disinterested witnesses. See Richards v. Hardin Cnty. Bd. of Rev., 393 N.W.2d 148, 151 (Iowa 1986) (applying the prior version of section 441.21(3)). The district court found Arconic made the required showing, so the burden of persuasion rested with the Board, and Arconic was not obliged to establish the correct value for it to prevail. Market analysis is preferred, but other factors may be considered if, and only if, market value cannot be readily established through the preferred market analysis, and once that threshold is crossed, no single factor may 9 control. Wellmark, Inc. v. Polk Cnty. Bd. of Rev., 875 N.W.2d 667, 679 (Iowa 2016). Here, the district court found that Arconic produced competent evidence that the assessment was excessive, which shifted the burden to the Board to uphold the valuation. That determination is not challenged on appeal, and the Board does not dispute that Arconic carried its initial burden. The dispositive questions are, what is the actual value of the property, and ultimately, was the assessment excessive? Arconic advances four principal grounds for disturbing the district court’s answer. We address each and conclude that none warrant reversal. I. The district court’s reliability determinations are entitled to deference and are supported by the record. Arconic contends that the district court’s choices among the appraisers were not credibility determinations owed any deference, but legal errors, because a property-tax appeal turns on competing methodologies rather than witness demeanor. We do not accept that framing. 1 Deciding which of several qualified appraisers reached the more reliable opinion of value—and how much weight to assign each of the recognized approaches— is the essence of the factfinding that valuation disputes require. Nationwide, 983 N.W.2d at 42. Our supreme court has repeatedly deferred to precisely that judgment. In Nationwide, the district court “found [the taxpayer’s] experts credible” but “found the Board’s experts more reliable” and “gave greater weight to the Board’s expert valuations, which more closely tracked the county assessor’s valuation”; the supreme court found “no basis to reject 1 One example survives that framing. The court rejected Jenkins’s sales comparison with the single observation that it “is simply too low to be considered” and gave no reason. Deference to a factfinder’s weighing presupposes findings specific enough to permit review, and we do not defer to a conclusory finding. We therefore weigh Jenkins’s analysis ourselves, along with the rest of the valuation evidence, in section III. 10 the district court’s determination about the relative reliability of the expert witness testimony or the court’s reliance on the reconciled values incorporating other factors in the analysis,” and held on that basis that “the Board met its burden to prove the valuation was not excessive.” 983 N.W.2d at 40, 42–44. Here, the district court’s treatment of the four appraisals was, for the most part, a reasoned weighing. It disregarded Fisher’s appraisal as an outlier and found her testimony unpersuasive. It gave no weight to the income approach and less weight to the cost approach given the property’s depreciation and obsolescence. And it found that although Helland selected the better comparable sales, he discounted the resulting value too severely. A factfinder confronted with conflicting appraisals is not required to average the divergent results; its task is to accept the evidence it finds most reliable and reject what it does not. See Heritage Cablevision v. Bd. of Rev., 457 N.W.2d 594, 597 (Iowa 1990). II. The district court applied the preferred sales-comparison approach and permissibly used the cost approach and the assessor’s testimony only as a check. Arconic argues that the ruling is internally inconsistent: having found the cost approach unreliable for this property, the district court could not then sustain a valuation the assessor derived from that very approach. But the court did not adopt any appraiser’s figure as the measure of value. It left the Riverdale parcel at the assessor’s valuation of $47,624,500, having tested that figure against Kirchner’s sales-derived $8.50 per square foot and found it “not excessive” and “fairly consistent with the Assessor’s value.” The assessor had arrived at his figure through a process that, as the court put it, 11 “resembles the cost approach.” The sales comparison thus served as a check on a cost-derived assessment rather than as the origin of the value. Iowa law does not forbid that sequence. Comparable sales are the preferred route to market value, and other factors may be consulted when market value cannot readily be established through market transactions. Wellmark, Inc., 875 N.W.2d at 682. To begin with an assessor’s figure and confirm it against the preferred method does not invert the statute, provided the confirming evidence is itself sound. That proviso applies here and the district court’s conclusion depends on the reliability of Kirchner’s sales comparison. We turn to it. Where the record shows that comparable sales alone cannot readily fix value, the factfinder may consider other factors, and the statute forbids resting “actual value” on a single factor. Nationwide, 983 N.W.2d at 43. Here, every appraiser developed more than one approach, and all agreed the property’s size and piecemeal construction sharply limited the pool of buyers and comparable transactions. In that setting, consulting the cost approach and the assessor’s methodology to test the reasonableness of a sales- comparison conclusion is the multi-factor inquiry the Code contemplates. See Iowa Code § 441.21(2). Assigning an approach “less weight” while still drawing on it as a cross-check reflects the reality that “there is no science in this determination, only judgment based on the record before us.” Wellmark, Inc., 875 N.W.2d at 683. III. The district court accounted for the deficiencies in Kirchner’s comparable sales, and the value it independently determined is supported by the record. Iowa law is clear that when sales of other properties are used, “the market value of the assessed property must be adjusted to account for 12 differences between the comparable property and the assessed property to the extent any differences would distort the market value . . . in the absence of such adjustments,” and that abnormal transactions must be adjusted to eliminate distorting factors. Soifer v. Floyd Cnty. Bd. of Rev., 759 N.W.2d 775, 783 (Iowa 2009). A comparable sale subject to a long-term lease raises “the question of whether the buyer was interested in the property or the income stream generated by an advantageous lease,” thereby “clouding comparability.” Wellmark, Inc., 875 N.W.2d at 682. The effect of a lease “must be considered as a factor in considering adjustments” to such a sale. Foreman & Clark of Iowa, Inc. v. Bd. of Rev., 286 N.W.2d 169, 173 (Iowa 1979). And where distorting factors “are not quantifiable so as to permit the required adjustment, the other property will not be considered comparable.” Soifer, 759 N.W.2d at 783. Because “property subject to a lease is taxed as a whole and measured by the value of the fee,” these adjustments protect the statutory command that the fee be valued, not an encumbered leasehold interest. Merle Hay Mall v. City of Des Moines Bd. of Rev., 564 N.W.2d 419, 422 (Iowa 1997); see Soifer, 759 N.W.2d at 780. Here, the district court identified this problem but did not resolve it. It found that Kirchner “had the most glaring issues with his sales comparison valuation,” that “[m]any of his comps were multitenant facilities,” and that “he was uncertain about whether the sales were in fee simple or a lease fee.” Soifer does not treat an unadjusted and unquantifiable difference as a question of weight alone; it removes the transaction from the comparable set. 759 N.W.2d at 783. The record establishes that the required adjustments were not made and, on this record, cannot now be made. Kirchner’s sales sheets do not identify the property rights conveyed, and he could not say whether 13 individual sales were fee simple or leased fee. He agreed that knowing the property rights conveyed “is necessary to know whether you need to make adjustments”; that had he known a number of his sales were leased fee he “would have made an adjustment under property rights conveyed”; that he made none; and that, because he does not know the lease terms, he cannot say even now whether the adjustment was warranted. He made no adjustment for market conditions although his sales ran from January 2018 to the January 2023 valuation date, and no adjustment for sales conditions on any property, including one sale out of bankruptcy—a category of transaction the statute itself singles out as requiring exclusion or adjustment. See Iowa Code § 441.21(1)(b). Where distorting factors cannot be quantified so as to permit the required adjustment, the transaction “will not be considered comparable.” Soifer, 759 N.W.2d at 783. We therefore give Kirchner’s sales comparison little weight. Our review is de novo and the burden of persuasion rested with the Board. Setting Fisher’s appraisal aside and discounting Kirchner’s sales comparison, the sales-derived evidence is Helland’s $40,600,000 and Jenkins’s $34,760,000; the cost approaches, to which the court gave little weight, range from $41,610,000 to $62,475,000. Weighing the evidence ourselves, we are satisfied that the Board carried its burden as to the Riverdale parcel. The assessor explained his methodology and was examined on it at trial; the district court found his account of the increase credible, logical, and consistent, and found that the property’s valuation had been held static in prior years while values in the relevant market rose. Helland’s conclusion, which the court declined to credit because it discounted land value far below every other appraiser’s, would leave the property worth less in 2023 than in 2022 against unrebutted evidence of an eleven to twenty 14 percent rise in the relevant market. On the whole record, we determine the actual value of the property as of January 1, 2023 to be $50,102,085. The district court’s treatment of the two parcels confirms that it determined value rather than ratifying the assessment. Every witness agreed the parcels function as a single economic unit, and Kirchner testified that he valued them separately only because the county assessor instructed him to. The 2023 assessment had nonetheless raised the Bettendorf parcel’s land valuation 141 percent and its improvements 151 percent while raising the Riverdale parcel’s by 14 and 18.5 percent, and the assessor “did not have any explanation for the disparate increase.” Finding “no compelling reason to treat these parcels differently,” the court applied the Riverdale increases to the Bettendorf parcel’s prior values, reducing that parcel from $5,264,700 to $2,477,585. Treating the economic unit consistently, and resolving the disparity in Arconic’s favor, was an appropriate exercise of the authority to determine value anew. IV. The district court did not presume the assessment correct or defer improperly to the assessor. Finally, Arconic contends that the district court effectively deferred to Assessor McManus and thereby afforded the County’s valuation a presumption of correctness that Iowa law forbids. Arconic is correct as to the governing principle. On de novo review, “[w]e operate under no presumption of correctness of the board’s determination,” and the district court was obligated to determine value anew. Ross v. Bd. of Rev., 417 N.W.2d 462, 466 (Iowa 1988). But the record does not reveal that the district court departed from that rule. The court independently rejected one of the county’s own appraisers outright, gave little or no weight to the income and cost approaches on which the county’s evidence largely rested, and reduced the 15 assessment the county sought to defend. Those are not the actions of a court presuming the county correct. Valley Forge Apartments v. Board of Review of Johnson County, which Arconic relies on does not require reversal, as the facts here are distinguishable. See 239 N.W.2d 148, 150 (Iowa 1976). There, the assessor and the board “relied almost exclusively on certain guidelines as to cost and other data prepared by its appraiser, Vanguard Appraisal Company, to the complete exclusion of evidence offered by” the taxpayer. Id. Such guidelines, the court held, “may not be the sole method by which a result is reached nor may they serve as a substitute for the exercise of the assessor’s judgment,” because the contrary rule “would make it virtually impossible for a taxpayer to successfully challenge a valuation of his property since actual cost figures would perforce give way to the appraiser’s all-purpose guidelines.” Id. at 151. The vice in Valley Forge was exclusive reliance on an all-purpose formula together with disregard of the taxpayer’s evidence. Neither occurred here. The assessor’s manual-derived figure was not the sole method by which the result was reached; it was tested against four independent appraisals and against the assessor’s own examination on the particulars of this property— the ninety percent reduction for unusable acres, the conservative depreciation, the classification of the plant as light rather than heavy manufacturing. Nor did the court disregard Arconic’s evidence. It found Helland’s comparable sales the best in the record, found Arconic’s showing sufficient to shift the burden, rejected one of the Board’s own appraisers outright, and cut the Bettendorf assessment by more than half. Last, Arconic’s objection that what other Scott County properties were assessed at has no bearing on what a willing buyer would pay for this facility is well taken. See Iowa Code § 441.21(1)(b). Indeed, evidence that 16 other parcels’ assessments rose by five percent per cycle is not market evidence, and parity among assessments is not a measure of actual value. But evidence that property values in the relevant market rose between eleven and twenty percent after the pandemic is market evidence: it speaks to the direction and magnitude of movement in the asset class and may properly inform a valuation. To the extent the district court’s reasoning rested on assessment parity, it was not a permissible basis for fixing this property’s value, and we do not rely on it. To the extent it rested on market movement, the court was entitled to weigh it, and so are we. A factfinder determining value anew may weigh the assessor’s testimony along with the appraisal evidence; considering that testimony is not the same as presuming the assessment valid. The district court reached its own conclusion of value, informed by but not bound to the assessor, and we see no reason to depart from that conclusion. CONCLUSION Reviewing the record de novo, and giving the district court’s credibility determinations the deference they are owed, we conclude that the court applied the appropriate governing framework, made a permissible independent determination of the property’s actual value, and did not clothe the assessment with any presumption of correctness. We independently determine the actual value of the property as of January 1, 2023, to be $50,102,085; $47,624,500 for the Riverdale parcel, and $2,477,585 for the Bettendorf parcel. We affirm. AFFIRMED. 17