Chatham County charged owners in its unincorporated fire district a flat amount per parcel or an amount based on a building’s square footage. Owners sought refunds, arguing that the so-called fire protection fee was an unlawful tax on real property. The Supreme Court of Georgia agreed. The charge funded a service available throughout the district and was imposed on property owners rather than tied to each owner’s use of fire protection, making it a tax despite its label. Under the applicable state constitution and general law, a county tax on real property in such a district had to be based on property value. Because this charge was not, the ordinance exceeded the county’s taxing authority. The court affirmed summary judgment for the owners; it did not prohibit the county from funding fire protection through a lawful tax.