Cite as: 505 U. S. 1 (1992)
Opinion of Thomas, J.
Allegheny Pittsburgh, then, does not prevent the State of California from classifying properties on the basis of their value at acquisition, so long as the classification is supported by a rational basis. I agree with the Court that it is, both for the reasons given by this Court, see ante, at 11-14, and for the reasons given by the Supreme Court of California in Amador Valley Joint Union High School Dist. v. State Bd. of Equalization, 22 Cal. 3d 208, 583 P. 2d 1281 (1978). But the classification employed by the Webster County assessor, indistinguishable from California's, was rational for all those reasons as well. In answering petitioner's argument that Allegheny Pittsburgh controls here, respondents offer a second explanation for that case. Justice Stevens gives much the same explanation, see post, at 31-32, though he concludes in the end that Proposition 13, after Allegheny Pittsburgh, is unconstitutional.
According to respondents, the Equal Protection Clause permits a State itself to determine which properties are similarly situated, as the State of California did here (classifying properties by acquisition value) and as the State of West Virginia did in Allegheny Pittsburgh (classifying properties by market value). But once a State does so, respondents suggest, the Equal Protection Clause requires after Allegheny Pittsburgh that properties in the same class be accorded seasonably equal treatment and not be intentionally and systematically undervalued. Proposition 13 provides for the assessment of properties in the same state-determined class regularly and at roughly full value; this contrasts with the tax scheme in Webster County, where by dividing property in the same class (by market value) into a subclass (by acquisition value), the assessor regularly under-valued the property similarly situated. This, according to respondents, made the Webster County scheme unconstitutional, and distinguishes Proposition 13.
Respondents' reading of Allegheny Pittsburgh is, in my view, as misplaced as petitioner's; their test, for starters,
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