8
Opinion of the Court
plaint, she alleged: "Article XIIIA has created an arbitrary system which assigns disparate real property tax burdens on owners of generally comparable and similarly situated properties without regard to the use of the real property taxed, the burden the property places on government, the actual value of the property or the financial capability of the property owner." Id., at 12. Respondents demurred. Id., at 14. By minute order, the Superior Court sustained the demurrer and dismissed the complaint without leave to amend. App. to Pet. for Cert. D2.
The California Court of Appeal affirmed. Nordlinger v. Lynch, 225 Cal. App. 3d 1259, 275 Cal. Rptr. 684 (1990). It noted that the Supreme Court of California already had rejected a constitutional challenge to the disparities in taxation resulting from Article XIIIA. See Amador Valley Joint Union High School Dist. v. State Bd. of Equalization, 22 Cal. 3d 208, 583 P. 2d 1281 (1978). Characterizing Article XIIIA as an "acquisition value" system, the Court of Appeal found it survived equal protection review, because it was supported by at least two rational bases: First, it prevented property taxes from reflecting unduly inflated and unforeseen current values, and, second, it allowed property owners to estimate future liability with substantial certainty. 225 Cal. App. 3d, at 1273, 275 Cal. Rptr., at 691-692 (citing Amador, 22 Cal. 3d, at 235, 583 P. 2d, at 1293).
The Court of Appeal also concluded that this Court's more recent decision in Allegheny Pittsburgh Coal Co. v. County Comm'n of Webster Cty., 488 U. S. 336 (1989), did not warrant a different result. At issue in Allegheny Pittsburgh was the practice of a West Virginia county tax assessor of assessing recently purchased property on the basis of its purlaw was this Court's decision in Allegheny Pittsburgh Coal Co. v. County Comm'n of Webster Cty., 488 U. S. 336 (1989), decided 9 months before petitioner filed her amended complaint. Because the California courts did not discuss whether petitioner's action was timely under § 4808, we do not do so.
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