Fitzgerald v. Racing Association of Central Iowa, 539 U.S. 103, 8 (2003)

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110

FITZGERALD v. RACING ASSN. OF CENTRAL IOWA

Opinion of the Court

tween this case and Allegheny Pittsburgh is the absence of any indication in Allegheny Pittsburgh that the policies underlying an acquisition-value taxation scheme could conceivably have been the purpose for the . . . unequal assessment." 505 U. S., at 14-15. The Court in Nordlinger added that "Allegheny Pittsburgh was the rare case where the facts precluded any plausible inference that the reason for the unequal assessment practice was to achieve the benefits of an acquisition-value tax scheme." Id., at 16-17, and n. 7. Here, "the facts" do not "preclud[e]" an inference that the reason for the different tax rates was to help the riverboat industry or the river communities. Id., at 16.

IV

We conclude that there is "a plausible policy reason for the classification," that the legislature "rationally may have . . . considered . . . true" the related justifying "legislative facts," and that the "relationship of the classification to its goal is not so attenuated as to render the distinction arbitrary or irrational." Id., at 11. Consequently the State's differential tax rate does not violate the Federal Equal Protection Clause. The Iowa Supreme Court's judgment to the contrary is reversed, and the case is remanded for further proceedings not inconsistent with this opinion.

So ordered.

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