Willard v. Pike
In Willard v. Pike, 59 Vt. 202, 9 A. 907 (1886), the exemption was challenged for several buildings owned by St. Johnsbury Academy that were currently used for a boarding house, a club house for students, and a future residence for the principal on the grounds that the buildings were not being used as required by the exemption.
The Court initially admitted that "our statute stands on the ground of ownership alone. There is no mention of use." Id. at 217, 9 A. at 915.
Despite this statement, the Court concluded:
"Although . . . ownership is all that is expressly required, it is probable that the legislature did not intend to exempt property simply because owned by an academy. In construing statutes of exemption from taxation, regard must be had to the settled rule that they are to be construed most strongly against those who claim their benefit. The ownership must undoubtedly be, not for speculative purposes, but for the appropriate use and benefit of the institution as an academy or a college in carrying out the purposes of its incorporation." (Id. at 218, 9 A. at 916.)
The Court allowed the exemption because what matters for the purposes of the statute is not only whether the property is owned by an educational entity, but also whether the property is used for an educational purpose.
The Court incorporated this recognized purpose into later holdings.