First, the case cited by the district court in support of "mass appraisal[s]" relates to the appraisal of undeveloped lots using the comparable sales method. In re Protest of Cobb , 1991–NMCA–122, ¶ 2, 113 N.M. 251, 824 P.2d 1053. Second, and more importantly, the district court's argument incorrectly shifts the burden of proof back to Appellant.
In reviewing the record presented, we must determine whether the Board's decision was "supported by substantial evidence or whether the decision is arbitrary, unlawful, unreasonable, or capricious." In re Protest of Cobb, 113 N.M. 251, 253, 824 P.2d 1053, 1055 (Ct.App. 1991). In making this determination, we will not substitute our own judgment.