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*********************************************** 
KENNETH A. BLACK v. TOWN OF WEST

HARTFORD ET AL.

(AC 43918)

Cradle, Suarez and Bear, Js.

Syllabus

The plaintiff appealed to the Superior Court from an assessment by the

Board of Assessment Appeals for the defendant town of West Hartford

in connection with certain of the plaintiff’s personal property. In his

appeal, the plaintiff also named as a defendant the state Office of Policy

and Management, claiming that it violated a certain statute (§ 12-71d)

in recommending the schedule of motor vehicle values the town used

to assess his vehicle. The Office of Policy and Management moved to

dismiss the action as against it and the trial court granted the motion

on the ground that the action was barred by the doctrine of sovereign

immunity. Held that the judgment of the trial court was affirmed on the

alternative ground that the plaintiff lacked standing to maintain the

action against the Office of Policy and Management because he was not

classically aggrieved; the personal and legal interest claimed by the

plaintiff, namely, the way in which vehicles are assessed for tax purposes, is common to all taxpayers, and not specific and personal to

the plaintiff, and apart from the Office of Policy and Management’s

recommendation that municipalities use a certain guide’s schedule to

assess vehicles, the plaintiff did not allege that the Office of Policy and

Management had any involvement in the assessment of the plaintiff’s

vehicle or any other vehicle, the plaintiff recognizing that it was the

responsibility of each municipality to perform that function.

Argued April 19—officially released July 13, 2021

Procedural History

Appeal from the decision of the named defendant’s

Board of Assessment Appeals revising the assessment

of certain of the plaintiff’s personal property, brought

to the Superior Court in the judicial district of Hartford,

where the court, Cobb, J., granted the motion to dismiss

filed by the defendant Office of Policy and Management

and rendered judgment thereon, from which the plaintiff appealed to this court. Affirmed.

Kenneth A. Black, self-represented, the appellant

(plaintiff).

Patrick T. Ring, assistant attorney general, with

whom were Joseph J. Chambers, deputy associate

attorney general, and, on the brief, William Tong, attorney general, and Clare E. Kindall, solicitor general, for

the appellee (defendant Office of Policy and Management).
Opinion

SUAREZ, J. The self-represented plaintiff, Kenneth

A. Black, appeals from the judgment of the trial court

dismissing his action as against the defendant Office of

Policy and Management for allegedly violating General

Statutes § 12-71d in recommending the schedule of

motor vehicle values that the defendant town of West

Hartford (town) used to assess his vehicle for the 2018

tax year.1 On appeal, the plaintiff claims that the court

erred in granting the defendant’s motion to dismiss on

the ground that the action was barred by the doctrine

of sovereign immunity. We affirm the judgment of the

court, but on the alternative ground that the plaintiff

lacks standing to maintain the action against the defendant. Because we affirm on this alternative ground, we

do not reach the trial court’s determination that the

action was barred by the defendant’s sovereign immunity.

The following facts, which either are undisputed or

are taken from the underlying complaint and viewed

in the light most favorable to the plaintiff; Godbout v.

Attanasio, 199 Conn. App. 88, 90–91, 234 A.3d 1031

(2020); are relevant to our consideration of the plaintiff’s claim on appeal. On October 21, 2019, the plaintiff,

pursuant to General Statutes § 12-117a,2

filed a complaint with the trial court appealing from the motor

vehicle assessment made by the town assessor and the

subsequent action of the town’s Board of Assessment

Appeals (board).3 The complaint alleged the following

facts. At all relevant times, the plaintiff was the owner

of a 2017 Subaru Crosstrek 2.0L Premium Automatic

(vehicle) that was registered in the town. On or about

July 1, 2019, the plaintiff received a property tax bill

for the vehicle covering the period of October 1, 2018

through September 30, 2019, in the amount of $645.39.

The town assessor valued the vehicle at $15,440, which,

pursuant to General Statutes § 12-62, was 70 percent

of the vehicle’s ‘‘present true and actual value.’’ On

September 12, 2019, the plaintiff appealed to the board

‘‘claiming to be aggrieved by the original valuation,’’

and the board reduced the vehicle’s assessed value to

$14,770. On September 16, 2019, the board sent a

‘‘Notice of Change of Assessment’’ reflecting this reduction to the plaintiff.4

The plaintiff next alleged that the defendant ‘‘is a

duly authorized agency of the State of Connecticut and

is responsible for recommending a schedule of motor

vehicle value which shall be used by the assessors in

each municipality pursuant to . . . [§] 12-71d.’’5 He

then alleged that, ‘‘[u]pon information and belief, the

[defendant] [is] not following . . . [§] 12-71d by basing

the motor vehicle tax on the National Automobile Dealers Association (NADA) ‘clean retail’ value instead of

the plain language of [§] 12-71d which requires motor

vehicle taxes to be based on the average retail price.’’
He further alleged that the ‘‘NADA ‘clean retail’ value

of [the plaintiff’s vehicle] was . . . $22,050. The base

[Manufacturer’s Suggested Retail Price (MSRP)] when

the vehicle was purchased in May of 2017 was $22,495.

. . . This means under the valuation scheme, the over

two year old vehicle has lost only $445 in value, or [2]

percent of its MSRP. The ‘clean retail’ value as defined

by the NADA does not state ‘average’ within the text

. . . .’’ To support this assertion, the plaintiff provided

in the complaint an excerpt that was allegedly taken

from the NADA guides’ website, which contained

answers to frequently asked questions about values and

pricing. The excerpt states: ‘‘Clean Retail values reflect

a vehicle in clean condition. This means a vehicle with

no mechanical defects and passes all necessary inspections with ease. Paint, body and wheels have minor

surface scratching with a high gloss finish and shine.

Interior reflects minimal soiling and wear with all equipment in complete working order. Vehicle has a clean

title history. Because individual vehicle condition varies

greatly, users of NADAguides.com may need to make

independent adjustments for actual vehicle condition.’’

The plaintiff attached four documents to the complaint and incorporated them by reference in his allegations.6 Among the attachments was a September 28,

2018 memorandum from the defendant to municipal

assessors in which the defendant, in accordance with

§ 12-71d, recommended a motor vehicle pricing schedule to be used for the 2018 Grand List. The memorandum recommended the use of the October, 2018 NADA

guides to value certain types of motor vehicles. The

memorandum stated that the schedules in the NADA

guides ‘‘reflect the 100 [percent] average retail price/

‘[c]lean [r]etail [v]alue’ of motor vehicles for the current

assessment year . . . . The assessment must reflect

[70] percent . . . of the recommended values.’’

Another attachment listed the NADA guides’ used car

values for the plaintiff’s make and model of vehicle

with 27,500 miles, as of October 1, 2018. This document

provided, among other things, multiple categories of

base values for this type of vehicle.7 The clean retail

value was the highest of these base values.

The complaint sought (1) ‘‘declaratory relief that the

assessment should be based on the average retail price

pursuant to . . . [§] 12-71d rather than [the] NADA

‘clean retail’ value,’’ (2) ‘‘[a] [r]efund of the plaintiff’s

overpayment of taxes, an amount less than [$2500],

exclusive of interest and costs,’’ (3) ‘‘[d]eclaratory and

other costs pursuant to [General Statutes §§] 12-117a

and 52-257, including service fees,’’ and (4) ‘‘[s]uch other

relief as injunction and equity appertains.’’

On November 18, 2019, the defendant, pursuant to

Practice Book § 10-30, moved to dismiss the plaintiff’s

claims for lack of subject matter jurisdiction, arguing

that ‘‘sovereign immunity completely bar[red] the plain-
tiff’s action against [it].’’8 The defendant also argued

that ‘‘the plaintiff ha[d] not exhausted his available

administrative remedies,’’ ‘‘the plaintiff lack[ed] standing to bring his claims against [the defendant] due to

lack of aggrievement,’’ and ‘‘the plaintiff’s claims against

[the defendant] are nonjusticiable because they are

not ripe.’’

On December 2, 2019, the plaintiff filed an objection

to the motion in which he disputed each of the defendant’s arguments. He argued in relevant part that sovereign immunity did not apply because the defendant

‘‘acted in excess and contrary to the plain language of

[§ 12-71d] . . . .’’ On the issue of standing, he argued

that he had been ‘‘personally aggrieved by [the]

improper tax valuation and failure of the [defendant]

to follow [§ 12-71d],’’ and provided a list comparing the

NADA clean retail value of his vehicle to the values of

the same vehicle contained in other guides.9 The plaintiff attached to his objection a letter that he purportedly

e-mailed to Martin L. Heft, a policy development coordinator in the defendant’s Intergovernmental Policy and

Planning Division, on June 30, 2019, with ‘‘questions

. . . in regard to [the defendant’s] role with [m]otor

[v]ehicle [a]ssessment valuation.’’ The last question in

the letter asked: ‘‘Why is the clean retail value used in

determining the average retail value?’’ He also attached

what he represented to be Heft’s reply, which stated in

relevant part: ‘‘NADA’s Used Car and Older Car Guides

do not list the average retail prices of vehicles. Instead,

they list ‘clean retail value.’ These terms are synonymous—NADA’s clean retail value has the same meaning

as the term average retail price or average retail value.’’

On December 10, 2019, the defendant filed a reply to

the plaintiff’s objection.

On January 13, 2020, the court heard oral argument

on the motion to dismiss.10 The defendant began by

arguing that the plaintiff had not exhausted his administrative remedies before bringing the action, and that

the plaintiff failed to plead an exception to the doctrine

of sovereign immunity.11 The defendant then addressed

its argument that the plaintiff did not have standing.12

Later in the hearing, the plaintiff addressed the defendant’s argument that he failed to exhaust his administrative remedies and that sovereign immunity barred the

action.

On January 31, 2020, the court granted the motion

to dismiss on the ground that the action was barred by

sovereign immunity. In its order granting the motion,

the court stated: ‘‘It is axiomatic that the state as the

sovereign cannot be sued without its consent. Allen v.

Commissioner of Revenue Services, 324 Conn. 292, 298,

[152 A.3d 488] (2016). Sovereign immunity applies to

the state and its agencies and officers. Id. To overcome

sovereign immunity the plaintiff must establish that the

legislature either expressly or by force of necessary
implication waived sovereign immunity or in an action

for declaratory or injunctive relief, the state or its officers acted in excess of their statutory authority or pursuant to an unconstitutional statute. DaimlerChrysler

Corp. v. Law, 284 Conn. 701, 711–12, [937 A.2d 675]

(2007). Here, the plaintiff does not allege that the state

has waived its sovereign immunity, [or refer to] any

statute that constitutes a waiver and has failed to allege

that the state or its officers acted in excess of their

statutory authority or pursuant to an unconstitutional

statute. See Carter v. Watson, 181 Conn. App. 637, 642,

[187 A.3d 478] (2018).’’ The court did not address the

merits of the defendant’s argument that the action

should be dismissed on the ground that the plaintiff

lacked standing. From that judgment, the plaintiff now

appeals. Additional facts and procedural history will be

set forth as necessary.

The plaintiff claims that the court erred in granting

the defendant’s motion to dismiss on the ground that

the action was barred by the doctrine of sovereign

immunity. The defendant argues that the court properly

dismissed the action on the ground of sovereign immunity. In the alternative, the defendant argues, as it did

before the trial court, that the judgment should be

affirmed because the plaintiff cannot establish that he

was aggrieved and, thus, had standing. We deem it

appropriate to uphold the trial court’s dismissal of the

action as to the defendant on the ground that the plaintiff lacked standing to bring the action against the defendant.13

‘‘Our Supreme Court has stated that [o]nly in [the]

most exceptional circumstances can and will this court

consider a claim, constitutional or otherwise, that has

not been raised and decided in the trial court. . . .

This rule applies equally to alternat[ive] grounds for

affirmance. . . . One such exceptional circumstance

is a claim that implicates the trial court’s subject matter

jurisdiction, which may be raised at any time and, thus,

is not subject to our rules of preservation.’’ (Citation

omitted; emphasis in original; internal quotation marks

omitted.) Board of Education v. Bridgeport, 191 Conn.

App. 360, 378–79 n.8, 214 A.3d 898 (2019). ‘‘[B]ecause

aggrievement implicates subject matter jurisdiction, [a]

possible absence of subject matter jurisdiction must be

addressed and decided whenever the issue is raised.’’

(Internal quotation marks omitted.) Wucik v. Planning & Zoning Commission, 113 Conn. App. 502, 506,

967 A.2d 572 (2009).

As we have observed, the defendant raised the issue

of standing before the trial court and the plaintiff had

an opportunity to, and did, address the issue of standing.

Moreover, the defendant raised the issue of standing

in its brief to this court and the plaintiff addressed

the issue in his reply brief.14 Accordingly, the issue of

standing is properly before this court despite the fact
that the trial court did not rely on that ground in dismissing the action. Our plenary review of the record persuades us that the plaintiff lacks standing to maintain

the action and, therefore, we affirm the court’s judgment of dismissal on this ground.

‘‘It is well established that a party must have standing

to assert a claim in order for the court to have subject

matter jurisdiction over the claim. . . . Standing is the

legal right to set judicial machinery in motion. One

cannot rightfully invoke the jurisdiction of the court

unless he has, in an individual or representative capacity, some real interest in the cause of action, or a legal

or equitable right, title or interest in the subject matter

of the controversy. . . . Standing . . . is not a technical rule intended to keep aggrieved parties out of court;

nor is it a test of substantive rights. Rather it is a practical concept designed to ensure that courts and parties

are not vexed by suits brought to vindicate nonjusticiable interests and that judicial decisions which may

affect the rights of others are forged in hot controversy,

with each view fairly and vigorously represented. . . .

Where a party is found to lack standing, the court is

consequently without subject matter jurisdiction to

determine the cause. . . .

‘‘When standing is put in issue, the question is

whether the person whose standing is challenged is a

proper party to request an adjudication of the issue

. . . . Because standing implicates the court’s subject

matter jurisdiction, the plaintiff . . . bears the burden

of establishing standing. . . . Our review of the question of the plaintiff’s standing is plenary.’’ (Citations

omitted; internal quotation markets omitted.) State

Marshal Assn. of Connecticut, Inc. v. Johnson, 198

Conn. App. 392, 398–99, 234 A.3d 111 (2020).

The defendant argues that the plaintiff lacks standing

because he has failed to establish classical

aggrievement. Specifically, the defendant argues that

the plaintiff cannot demonstrate that he has a ‘‘specific,

personal, and legally protected interest’’ in the matter,

and that, even if he could, he ‘‘did not allege an actual

harm’’ that was caused by its actions. To support its

argument, the defendant states that the ‘‘schedule is

created by [the defendant] for use in every municipality

in this state. It is not applied solely to the plaintiff’s

property, or exclusively in one municipality. That is,

the plaintiff’s interests with respect to [the defendant’s]

recommended schedule are no different from every

other taxpayer in the state. Indeed, the plaintiff’s claims

are similar to general ‘taxpayer standing’ claims, which

the courts have historically and routinely rejected.’’ The

defendant further states that it ‘‘does not administer

the tax at issue,’’ and contends that it has not ‘‘imposed

assessed values that are set in stone and cannot be

altered.’’ It points to the fact that ‘‘the initial determination of a vehicle’s value still rests with the municipal
assessors,’’ and that these assessments ‘‘are subject to

review by the municipalities’ boards of assessment

appeals, which can alter the assessed values as necessary.’’ Accordingly, the defendant argues, it ‘‘is not, and

could not be, the cause of any injury here.’’ In his reply

brief to this court, the plaintiff quotes from his objection

to the defendant’s motion to dismiss to reiterate that

he has been aggrieved by the defendant’s ‘‘direct [role]

in administering [the] tax bill . . . .’’ He argues that he

has standing because he has a personal interest in the

property that was taxed and that the burden is solely

on him to ‘‘pay, appeal, and now bring [this matter] to

court.’’ We agree with the defendant.

‘‘It is axiomatic that aggrievement is a basic requirement of standing, just as standing is a fundamental

requirement of jurisdiction. . . . There are two general

types of aggrievement, namely, classical and statutory;

either type will establish standing, and each has its own

unique features. . . . Classical aggrievement requires

a two part showing. First, a party must demonstrate a

specific, personal and legal interest in the subject matter of the [controversy], as opposed to a general interest

that all members of the community share. . . . Second,

the party must also show that the [alleged conduct] has

specially and injuriously affected that specific personal

or legal interest. . . . Statutory aggrievement exists by

legislative fiat, not by judicial analysis of the particular

facts of the case. In other words, in cases of statutory

aggrievement, particular legislation grants standing to

those who claim injury to an interest protected by that

legislation. . . . Aggrievement is established if there is

a possibility, as distinguished from a certainty, that

some legally protected interest . . . has been

adversely affected.’’ (Citations omitted; emphasis in

original; internal quotation marks omitted.) Trikona

Advisers Ltd. v. Haida Investors Ltd., 318 Conn. 476,

485–86, 122 A.3d 242 (2015).

In the present case, the plaintiff did not claim statutory aggrievement as a basis for the trial court’s jurisdiction in the underlying complaint, in his main brief or

reply brief to this court, or at oral argument before this

court. Rather, his arguments on the issue of standing

focus on classical aggrievement. Therefore, we consider

whether he has been classically aggrieved by the defendant’s recommendation that the municipalities of this

state, including, but not limited to, the town, should

apply the NADA guides’ schedule that includes the

‘‘clean retail values’’ of motor vehicles, as opposed to

their ‘‘average retail prices.’’ In the complaint, the plaintiff challenges only the defendant’s act of choosing the

‘‘clean retail value’’ portion of the motor vehicle pricing

schedule, and there is no allegation that the defendant

itself could apply or did apply any terms of that schedule

to determine the value of the plaintiff’s vehicle or any

other vehicle, the plaintiff recognizing that it was the

responsibility of each municipality to perform that func-
tion.15 The NADA guides recommended by the defendant cover numerous makes and models of vehicles16

that are registered in the state.17 Thus, the defendant’s

act of choosing the 2018 NADA guides as its recommended motor vehicle pricing schedule affected every

taxpayer whose vehicle was included in these guides.

The plaintiff does not allege that the defendant played

a role in assessing his vehicle beyond merely recommending the use of the ‘‘clean retail value’’ portion of

the NADA guides. In other words, the plaintiff does

not allege any affirmative conduct by the defendant

determining or requiring that his vehicle should be valued in a manner different from any of the other vehicles

registered with the town that are included in the NADA

guides. As previously noted in this opinion, when the

defendant issued its memorandum recommending the

motor vehicle pricing schedule for 2018, it stated that

the NADA guides contain the ‘‘average retail price/

‘[c]lean [r]etail [v]alue’ ’’ of the vehicles included

therein. Furthermore, Heft’s e-mail to the plaintiff states

that the relevant NADA guides ‘‘do not list the average

retail prices of vehicles,’’ and, instead, list ‘‘clean retail

value,’’ which ‘‘has the same meaning as the term average retail price . . . .’’ On the basis of this information,

we reasonably can infer that, for the 2018 tax year,

municipal assessors used clean retail values to formulate assessments for every vehicle included in the NADA

guides. Furthermore, on the basis of the excerpt from

the NADA guides’ website that the plaintiff provided in

the complaint, we reasonably can infer that the clean

retail values of every vehicle are calculated using the

same criteria. Thus, accepting as true the plaintiff’s

allegation that ‘‘clean retail value’’ is different than

‘‘average retail price,’’ he is unable to show how his

injury is different than that of any other taxpayer whose

vehicle is included in the NADA guides. Rather, the

personal and legal interest that the plaintiff claims to

have in the subject matter is one that is common to all

of these taxpayers. Accordingly, we conclude that the

plaintiff lacks standing to maintain the action as against

the defendant because he has failed to establish classical aggrievement under the first prong of the test.

In light of our conclusion that the plaintiff failed

to establish that he was aggrieved by the defendant’s

conduct, we conclude that the trial court lacked jurisdiction over the action as against the defendant and,

thus, should have dismissed it on that ground.18 See

Gershon v. Back, 201 Conn. App. 225, 244, 242 A.3d

481 (2020) (‘‘[w]henever a court finds that it has no

jurisdiction, it must dismiss the case’’ (internal quotation marks omitted)). Accordingly, we affirm the judgment of the trial court.

The judgment is affirmed.

In this opinion the other judges concurred.

1 The plaintiff also brought the action against the town for its role in
assessing his vehicle. As we discuss later in this opinion, the action was

not dismissed as against the town, and, at the time the plaintiff brought the

present appeal, the action was still pending against the town. Because the

litigation between the plaintiff and the town continued after judgment was

rendered in favor of the Office of Policy and Management, the town is

not participating in this appeal. We thus refer to the Office of Policy and

Management as the defendant.

2 General Statutes § 12-117a provides in relevant part: ‘‘Any person . . .

claiming to be aggrieved by the action of . . . the board of assessment

appeals . . . in any town or city may, within two months from the date of

the mailing of notice of such action, make application, in the nature of an

appeal therefrom . . . to the superior court for the judicial district in which

such town or city is situated, which shall be accompanied by a citation to

such town or city to appear before said court.’’

3 We generally will refer only to the portions of the complaint that are

relevant to the defendant, and not to the portions that are relevant to

the town.

4 The plaintiff alleged that he ‘‘believes the revised assessment in the

Notice of Change of Assessment is due to the vehicle having a mileage of

approximately 46,430 at the time of appeal, a higher value than the October

1, 2018 assessed assumed mileage of 27,500.’’

5 General Statutes § 12-71d provides in relevant part that the secretary of

the defendant ‘‘shall recommend a schedule of motor vehicle values which

shall be used by assessors in each municipality in determining the assessed

value of motor vehicles for purposes of property taxation. . . . The value

for each motor vehicle as listed shall represent one hundred per cent of

the average retail price applicable to such motor vehicle . . . .’’ (Emphasis added.)

6 The first attachment is the July 1, 2019 tax bill that the plaintiff received

from the town. The second attachment is the Notice of Change of Assessment

that the plaintiff received from the board.

7 The categories are low auction, average auction, high auction, rough

trade-in, average trade-in, clean trade-in, clean loan, and clean retail.

8 The town filed its own motion to dismiss, which is not relevant to

this appeal.

9 The plaintiff provided a total of seven values from Consumer Reports,

Kelley Blue Book, and Edmunds. These values were for vehicles with 50,000

miles in either ‘‘good’’ or ‘‘average’’ condition. Each value was less than the

NADA clean retail value.

10 At the hearing, the court also heard argument on the town’s motion to

dismiss. The court spent the majority of the hearing discussing that motion.

11 Although they are not applicable to the present appeal, there are three

exceptions to the sovereign immunity enjoyed by the state: ‘‘(1) [W]hen the

legislature, either expressly or by force of a necessary implication, statutorily

waives the state’s sovereign immunity . . . (2) when an action seeks declaratory or injunctive relief on the basis of a substantial claim that the state

or one of its officers has violated the plaintiff’s constitutional rights . . .

and (3) when an action seeks declaratory or injunctive relief on the basis

of a substantial allegation of wrongful conduct to promote an illegal purpose

in excess of the officer’s statutory authority.’’ (Citations omitted; internal

quotation marks omitted.) Columbia Air Services, Inc. v. Dept. of Transportation, 293 Conn. 342, 349, 977 A.2d 636 (2009).

12 Specifically, the defendant’s attorney argued: ‘‘[A]ggrievement requires

a specific personal legal interest . . . as opposed to the community as a

whole. And [the plaintiff] has to show that [he] has been specially and

injuriously affected by the agency’s action . . . .’’ The court then asked:

‘‘But isn’t [the plaintiff] claiming that? Isn’t this all about his assessment

appeal involving his motor vehicle?’’ The defendant’s attorney replied: ‘‘It

is, but that appeal is not concluded. I mean, I don’t actually know what he’s

claiming his damage is in this case.’’ The defendant’s attorney went on to

argue that the defendant ‘‘ha[d] been kind of bootstrapped along into the

matter’’ as ‘‘part of the process of [the plaintiff] challenging the [board’s]

valuation [of his vehicle] . . . .’’

13 This court may uphold a decision on an alternative legal ground. See

Florian v. Lenge, 91 Conn. App. 268, 281, 880 A.2d 985 (2005) (‘‘[i]t is

axiomatic that [w]e may affirm a proper result of the trial court for a different

reason’’ (internal quotation marks omitted)).

14 Additionally, this court, during oral argument, asked the plaintiff to

respond to the defendant’s argument that he did not have standing to bring

the action as against the defendant.
15 At the January 13, 2020 hearing on the motion to dismiss, the court

asked the plaintiff: ‘‘So . . . did you bring this [action] because you think

that the value on your car is too high because [the town] used the wrong

standard?’’ The plaintiff replied: ‘‘Correct. I maintain that clean retail, as

specified by the NADA, is higher than average retail value as specified in

the statute.’’ The plaintiff thus alleges that the town, and not the defendant,

applied the relevant portions of the schedule in its determination of the

value of his vehicle.

16 The defendant’s September 28, 2018 memorandum recommending the

use of the NADA guides states that they include ‘‘domestic cars, imported

cars, light and medium duty trucks, 100, 200, and 300 series vans and minivans . . . motorcycles, snowmobiles and all-terrain vehicles . . . motors

homes, travel trailers and camping trailers.’’

17 Some vehicles are not included in the NADA guides. General Statutes

§ 12-71d provides in relevant part: ‘‘For every vehicle not listed in the schedule the determination of the assessed value of any motor vehicle for purposes

of the property tax assessment list in any municipality shall continue to be

the responsibility of the assessor in such municipality . . . .’’

18 ‘‘It is axiomatic that, in resolving the issue of a party’s standing to

maintain a cause of action, we do not consider the merits of that action.’’

State Marshal Assn. of Connecticut, Inc. v. Johnson, supra, 198 Conn. App.

424 n.16 (2020).