Cite as: 505 U. S. 1 (1992)
Stevens, J., dissenting
number of economically vulnerable families is "rationally furthered" by a tax windfall for all 9,787,887 property owners 7 in California.
The Court's conclusion is unsound not only because of the lack of numerical fit between the posited state interest and Proposition 13's inequities but also because of the lack of logical fit between ends and means. Although the State may have a valid interest in preserving some neighborhoods,8 Proposition 13 not only "inhibit[s the] displacement" of settled families, it also inhibits the transfer of unimproved land, abandoned buildings, and substandard uses. Thus, contrary to the Court's suggestion, Proposition 13 is not like a zoning system. A zoning system functions by recognizing different uses of property and treating those different uses differently. See Euclid v. Ambler Realty Co., 272 U. S., at 388-390. Proposition 13 treats all property alike, giving all owners tax breaks, and discouraging the transfer or improvement of all property—the developed and the dilapidated, the neighborly and the nuisance.
In short, although I agree with the Court that "neighborhood preservation" is a legitimate state interest, I cannot agree that a tax windfall for all persons who purchased property before 1978 rationally furthers that interest. To my mind, Proposition 13 is too blunt a tool to accomplish such a
7 Brief for California Assessors' Association as Amicus Curiae 2.
8 The ambiguous character of this interest is illustrated by the options faced by a married couple that owns a three- or four-bedroom home that suited their family needs while their children lived at home. After the children have moved out, increased taxes and maintenance expenses would—absent Proposition 13—tend to motivate the sale of the home to a younger family needing a home of that size, or perhaps the rental of a room or two to generate the income necessary to pay taxes. Proposition 13, however, subsidizes the wasteful retention of unused housing capacity, making the sale of the home unwise and the rental of the extra space unnecessary.
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