KAHN v. SHEVIN - 416 U.S. 351, 94 S. Ct. 1734 (1974)

Rule:

Where taxation is concerned and no specific federal right, apart from equal protection, is imperiled, the states have large leeway in making classifications and drawing lines which in their judgment produce reasonable systems of taxation. A state tax law is not arbitrary although it discriminates in favor of a certain class if the discrimination is founded upon a reasonable distinction, or difference in state policy, not in conflict with the United States Constitution. 

Facts:

A Florida statute grants widows, but not widowers, an annual $ 500 property tax exemption. The plaintiff, a widower, applied for exemption to the Tax Assessor's Office, but his application was denied because the statute offers no analogous benefit for widowers. The plaintiff then sought a declaratory judgment in the Circuit Court for Dade County; that court held the statute violative of the equal protection clause of the Fourteenth Amendment because the classification "widow" was based upon gender. The Florida Supreme Court reversed, finding the classification valid because it has a fair and substantial relation to the object of the legislation, that is, the reduction of the disparity between the economic capabilities of a man and a woman.

Issue:

Was the tax statute that allowed an exemption for widows violative of the Equal Protection Clause of the Fourteenth Amendment because the classification "widow" was based upon gender?

Answer:

No

Conclusion:

The Court ruled in favor of the Attorney General, finding that Florida was attempting to bring balance to the disparity between economic capabilities of men and women by allowing the tax exemption only to widows. The Court held that the Florida's differing treatment of widows and widowers rested upon grounds that had a fair and substantial relation to the object of the legislation. The Court also found that tax laws were permitted to discriminate in favor of a certain class if the discrimination was founded upon a reasonable distinction or difference in state policy that was not in conflict with the United States Constitution.