16
Opinion of the Court
ers, 358 U. S. 522, 528-529 (1959). See also Schweiker v. Wilson, 450 U. S. 221, 235 (1981) (classificatory scheme must "rationally advanc[e] a reasonable and identifiable governmental objective" (emphasis added)). Allegheny Pittsburgh was the rare case where the facts precluded any plausible inference that the reason for the unequal assessment practice was to achieve the benefits of an acquisition-value tax scheme.7 By contrast, Article XIIIA was enacted precisely to achieve the benefits of an acquisition-value system. Allegheny Pittsburgh is not controlling here.8
Finally, petitioner contends that the unfairness of Article XIIIA is made worse by its exemptions from reassessment for two special classes of new owners: persons aged 55 and older, who exchange principal residences, and children who acquire property from their parents. This Court previously has declined to hold that narrow exemptions from a general scheme of taxation necessarily render the overall scheme in-7 In Allied Stores of Ohio, Inc. v. Bowers, 358 U. S. 522 (1959), the Court distinguished on similar grounds its decision in Wheeling Steel Corp. v. Glander, 337 U. S. 562 (1949), which invalidated a state statutory scheme exempting from taxation certain notes and accounts receivable owned by residents of the State but not notes and accounts receivable owned by nonresidents. 358 U. S., at 529. After the Court in Wheeling Steel determined that the statutory scheme's stated purpose was not legitimate, the other purposes did not need to be considered because "[h]aving themselves specifically declared their purpose, the Ohio statutes left no room to conceive of any other purpose for their existence." 358 U. S., at 530.
8 In finding Allegheny Pittsburgh distinguishable, we do not suggest that the protections of the Equal Protection Clause are any less when the classification is drawn by legislative mandate, as in this case, than by administrative action, as in Allegheny Pittsburgh. See Sunday Lake Iron Co. v. Township of Wakefield, 247 U. S. 350, 352 (1918). Nor do we suggest that the Equal Protection Clause constrains administrators, as in Allegheny Pittsburgh, from violating state law requiring uniformity of taxation of property. See Nashville, C. & St. L. R. Co. v. Browning, 310 U. S. 362, 368-370 (1940); Puget Sound Power & Light Co. v. County of King, 264 U. S. 22, 27-28 (1924). See generally Snowden v. Hughes, 321 U. S. 1, 8-11 (1944).
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