20
Opinion of Thomas, J.
tween the assessments of a class of property holders." 488 U. S., at 343. "[T]he constitutional requirement is the seasonable attainment of a rough equality in tax treatment of similarly situated property owners." Ibid. (citing Allied Stores of Ohio, Inc. v. Bowers, 358 U. S. 522, 526-527 (1959)). Moreover, the Court stated, the Constitution and laws of West Virginia "provide that all property of the kind held by petitioners shall be taxed at a rate uniform throughout the State according to its estimated market value," and "[t]here [was] no suggestion . . . that the State may have adopted a different system in practice from that specified by statute." 488 U. S., at 345. "Indeed, [the assessor's] practice seems contrary to that of the guide published by the West Virginia Tax Commission as an aid to local assessors in the assessment of real property." Ibid.; see also ibid. ("We are not advised of any West Virginia statute or practice which authorizes individual counties of the State to fashion their own substantive assessment policies independently of state statute"). The Court refused to decide "whether the Webster County assessment method would stand on a different footing if it were the law of a State, generally applied, instead of the aberrational enforcement policy it appears to be." Id., at 344, n. 4. Finally, the Court declared: " '[I]ntentional systematic undervaluation by state officials of other taxable property in the same class contravenes the constitutional right of one taxed upon the full value of his property.' " Id., at 345 (quoting Sunday Lake Iron Co. v. Township of Wakefield, 247 U. S. 350, 352-353 (1918), and citing Sioux City Bridge Co. v. Dakota County, 260 U. S. 441 (1923); Cumberland Coal Co. v. Board of Revision of Tax Assessments in Greene County, 284 U. S. 23 (1931)). The Court concluded that the assessments for the coal companies' properties had failed these requisites of the Equal Protection Clause.
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