Nordlinger v. Hahn, 505 U.S. 1, 28 (1992)

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28

NORDLINGER v. HAHN

Stevens, J., dissenting

ways Corp. of Del., 450 U. S. 662, 702-706, and n. 13 (1981) (Rehnquist, J., dissenting). This basis need not be one identified by the State itself; in fact, States need not articulate any reasons at all for their actions. See ibid. Proposition 13, I believe, satisfies this standard—but so, for the same reasons, did the scheme employed in Webster County. See Brief for Pacific Legal Foundation et al. as Amici Curiae 7, 9-10, Brief for National Association of Counties et al. as Amici Curiae 9-13, and Brief for Respondent 31-32, in Allegheny Pittsburgh Coal Co. v. County Comm'n of Webster County, O. T. 1988, Nos. 87-1303, 87-1310; ante, at 11-14. Allegheny Pittsburgh appears to have survived today's decision. I wonder, though, about its legacy.

* * *

I concur in the judgment of the Court and join Part II-A of its opinion.

Justice Stevens, dissenting.

During the two past decades, California property owners have enjoyed extraordinary prosperity. As the State's population has mushroomed, so has the value of its real estate. Between 1976 and 1986 alone, the total assessed value of California property subject to property taxation increased tenfold.1 Simply put, those who invested in California real estate in the 1970's are among the most fortunate capitalists in the world.

Proposition 13 has provided these successful investors with a tremendous windfall and, in doing so, has created se-1 Glennon, Taxation and Equal Protection, 58 Geo. Wash. L. Rev. 261, 270, n. 49 (1990). "For the same period, [property values in] Hawaii rose approximately 450%; Washington, D. C. approximately 350%; and New York approximately 125%." Ibid. (citing 2 U. S. Dept. of Commerce, Bureau of Census, Taxable Property Values 86-111 (1987) (Table 12); 2 U. S. Dept. of Commerce, Bureau of Census, Taxable Property Values and Assessment/Sales Price Ratios 42 (1977) (Table 2)).

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