Cite as: 505 U. S. 1 (1992)
Opinion of Thomas, J.
sonable attainment of a rough equality in tax treatment" or if it results in " 'intentional systematic undervaluation' " of properties similarly situated by state law. 488 U. S., at 343, 345. This would be so regardless of whether the inequality or the undervaluation, which may result (as in Webster County) from further classifications of properties within a class, is supported by a rational basis. But not since the coming of modern equal protection jurisprudence has this Court supplanted the rational judgments of state representatives with its own notions of "rough equality," "undervaluation," or "fairness." Cumberland Coal, which fails even to mention rational-basis review, conflicts with our current case law. Allegheny Pittsburgh did not, in my view, mean to return us to the era when this Court sometimes second-guessed state tax officials. In rejecting today respondents' reading of Allegheny Pittsburgh, the Court, as I understand it, agrees.
This brings me to the third explanation for Allegheny Pittsburgh, the one offered today by the Court. The Court proceeds in what purports to be our standard equal protection framework, though it reapplies an old, and to my mind discredited, gloss to rational-basis review. The Court concedes that the "Equal Protection Clause does not demand for purposes of rational-basis review that a legislature or governing decisionmaker actually articulate at any time the purpose or rationale supporting its classification." Ante, at 15 (citing United States Railroad Retirement Bd. v. Fritz, 449 U. S. 166, 179 (1980)). This principle applies, the Court acknowledges, not only to an initial classification but to all further classifications within a class. "Nevertheless, this Court's review does require that a purpose may conceivably or 'may reasonably have been the purpose and policy' of the relevant governmental decisionmaker," the Court says, ante, at 15 (quoting Allied Stores, supra, at 528-529), and "Allegheny Pittsburgh was the rare case where the facts precluded any plausible inference that the reason for the un-
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