Fitzgerald v. Racing Association of Central Iowa, 539 U.S. 103, 4 (2003)

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Opinion of the Court

cent tax rate difference that it created violated the Federal Constitution's Equal Protection Clause, Amdt. 14, 1. The State District Court upheld the statute. The Iowa Supreme Court disagreed and, by a 4-to-3 vote, reversed the District Court. The majority wrote that the "differential tax completely defeats the alleged purpose" of the statute, namely, "to help the racetracks recover from economic distress," that there could "be no rational reason for this differential tax," and that the Equal Protection Clause consequently forbids its imposition. 648 N. W. 2d, at 560-562. We granted certiorari to review this determination.


Respondents initially claim that the Iowa Supreme Court's decision rests independently upon state law. And they argue that this state-law holding bars review of the federal issue. We disagree. The Iowa Supreme Court's opinion, after setting forth the language of both State and Federal Equal Protection Clauses, says that "Iowa courts are to 'apply the same analysis in considering the state equal protection claims as . . . in considering the federal equal protection claim.' " Id., at 558. We have previously held that, in such circumstances, we shall consider a state-court decision as resting upon federal grounds sufficient to support this Court's jurisdiction. See Pennsylvania v. Muniz, 496 U. S. 582, 588, n. 4 (1990) (no adequate and independent state ground where the court says that state and federal constitutional protections are " 'identical' "). Cf. Michigan v. Long, 463 U. S. 1032, 1041-1042 (1983) ( jurisdiction exists where federal cases are not "being used only for the purpose of guidance" and instead are "compel[ling] the result"). We therefore find that this Court has jurisdiction to review the Iowa Supreme Court's determination.


We here consider whether a difference in state tax rates violates the Fourteenth Amendment's mandate that "[n]o

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