Cite as: 505 U. S. 1 (1992)
Stevens, J., dissenting
treatment between newer and older owners rationally furthers a legitimate state interest." Ante, at 11.3
But deference is not abdication and "rational-basis scrutiny" is still scrutiny. Thus we have, on several recent occasions, invalidated tax schemes under such a standard of review. See, e. g., Allegheny Pittsburgh Coal Co. v. County Comm'n of Webster Cty., 488 U. S. 336 (1989); Hooper v. Bernalillo County Assessor, 472 U. S. 612, 618 (1985); Williams v. Vermont, 472 U. S. 14 (1985); Metropolitan Life Ins. Co. v. Ward, 470 U. S. 869 (1985); cf. Zobel v. Williams, 457 U. S. 55, 60-61 (1982).
Just three Terms ago, this Court unanimously invalidated Webster County, West Virginia's assessment scheme under rational-basis scrutiny. Webster County employed a de facto Proposition 13 assessment system: The county assessed recently purchased property on the basis of its purchase price but made only occasional adjustments (averaging 3-4% per year) to the assessments of other properties. Just as in this case, "[t]his approach systematically produced dramatic differences in valuation between . . . recently transferred property and otherwise comparable surrounding land." Allegheny Pittsburgh, 488 U. S., at 341.
The " '[i]ntentional systematic undervaluation,' " id., at 345, found constitutionally infirm in Allegheny Pittsburgh has been codified in California by Proposition 13. That the discrimination in Allegheny Pittsburgh was de facto and the discrimination in this case de jure makes little difference. "The purpose of the equal protection clause of the Fourteenth Amendment is to secure every person within the
3 As the Court notes, ante, at 10, petitioner contends that Proposition 13 infringes on the constitutional right to travel and that, accordingly, a more searching standard of review is appropriate. There is no need to address that issue because the gross disparities created by Proposition 13 do not pass even the most deferential standard of review. Cf. Hooper v. Bernalillo County Assessor, 472 U. S. 612, 618 (1985); Zobel v. Williams, 457 U. S. 55, 60-61 (1982).
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