Fitzgerald v. Racing Association of Central Iowa, 539 U.S. 103, 7 (2003)

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Cite as: 539 U. S. 103 (2003)

Opinion of the Court

an end" once the court identifies a plausible basis on which the legislature may have relied); Nordlinger, supra, at 17-18.

Once one realizes that not every provision in a law must share a single objective, one has no difficulty finding the necessary rational support for the 20 percent/36 percent differential here at issue. That difference, harmful to the racetracks, is helpful to the riverboats, which, as respondents concede, were also facing financial peril, Brief for Respondents 8. See also 648 N. W. 2d, at 557. These two characterizations are but opposite sides of the same coin. Each reflects a rational way for a legislator to view the matter. And aside from simply aiding the financial position of the riverboats, the legislators may have wanted to encourage the economic development of river communities or to promote riverboat history, say, by providing incentives for riverboats to remain in the State, rather than relocate to other States. See Gaming Study Committee Report (Sept. 3, 1993), reprinted in App. 76-84, 86. Alternatively, they may have wanted to protect the reliance interests of riverboat operators, whose adjusted slot machine revenue had previously been taxed at the 20 percent rate. All these objectives are rational ones, which lower riverboat tax rates could further and which suffice to uphold the different tax rates. See Allied Stores, supra, at 528; Nordlinger, supra, at 12. See also Madden v. Kentucky, 309 U. S. 83, 88 (1940) (imposing burden on respondents to "negative every conceivable basis" that might support different treatment).

Respondents argue that Allegheny Pittsburgh Coal Co. v. Commission of Webster Cty., 488 U. S. 336 (1989), holds to the contrary. Brief for Respondents 21. In that case, the Court held that substantial differences in the level of property tax assessments that West Virginia imposed upon similar properties violated the Federal Equal Protection Clause. But the Court later stated, when it upheld in Nordlinger a California statute creating similar differences in property taxes, that "an obvious and critical factual difference be-


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