Constitutional Law — equal protection

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U.S. Supreme Court

Civil

Constitutional Law — equal protection

A city did not violate the Equal Protection Clause by changing its method of sewer financing, and not refunding money some taxpayers had already paid under the old system.

Administrative concerns can ordinarily justify a tax-related distinction, see, e.g., Carmichael v. Southern Coal & Coke Co., 301 U. S. 495–512, and the City’s decision to stop collecting outstanding Barrett Law debts finds rational support in the City’s administrative concerns. After the City switched to the STEP system, any decision to continue Barrett Law debt collection could have proved complex and expensive. It would have meant maintaining an administrative system for years to come to collect debts arising out of 20-plus different construction projects built over the course of a decade, involving monthly payments as low as $25 per household, with the possible need to maintain credibility by tracking down defaulting debtors and bringing legal action. The rationality of the City’s distinction draws further support from the nature of the line-drawing choices that confronted it. To have added refunds to forgiveness would have meant adding further administrative costs, namely the cost of processing refunds. And limiting refunds only to Brisbane/Manning homeowners would have led to complaints of unfairness, while expanding refunds to the apparently thousands of other Barrett Law project homeowners would have involved an even greater administrative burden. Finally, the rationality of the distinction draws support from the fact that the line that the City drew—distinguishing past payments from future obligations—is well known to the law. See, e.g., 26 U. S. C. §108(a)(1)(E).

946 N. E. 2d 553, affirmed.

11-161 Armour v. City of Indianapolis

Breyer, J.; Roberts, C.J., dissenting.