Law School Case Brief
Nordlinger v. Hahn - 505 U.S. 1, 112 S. Ct. 2326 (1992)
The equal protection clause of the Fourteenth Amendment, U.S. Const. amend. XIV, commands that no state shall deny to any person within its jurisdiction the equal protection of the laws. Of course, most laws differentiate in some fashion between classes of persons. The equal protection clause does not forbid classifications. It simply keeps governmental decisionmakers from treating differently persons who are in all relevant respects alike.
The real property tax assessment system established by a 1978 amendment to the California Constitution generally combined a 1 percent ceiling on real property tax rates based on assessed valuations for the 1975-1976 tax year with a 2 percent cap on annual increases in assessed valuations, subject to an exception that new construction or a change in ownership generally triggered a reassessment up to the current appraised value. Two exemptions were authorized from the reassessment requirement for (1) persons aged 55 and older who exchanged principal residences, and (2) children who acquired property from their parents. Stephanie Nordlinger, a Los Angeles County homeowner exhausted her administrative remedies and brought suit in the Los Angeles County Superior Court against defendants including the county tax assessor, Kenneth Hahn. Nordlinger (1) sought a tax refund and a declaration that the California constitutional amendment's assessment system violated the equal protection clause of the Federal Constitution's Fourteenth Amendment, and (2) alleged that after she had purchased her home in 1988, she was paying about five times more in taxes than neighbors who had owned comparable homes within the same residential district since 1975. The Superior Court, however, sustained a demurrer and dismissed the complaint without leave to amend. On appeal, the Court of Appeal of California, Second Appellate District, in affirming, expressed the view that the assessment system survived equal protection review, because the system was supported by at least two rational bases, in that the system (1) prevented property taxes from reflecting unduly inflated and unforeseen current values; and (2) allowed property owners to estimate future liability with substantial certainty. The Supreme Court of California denied review.
Did California's real property taxation system, which treated newer and older owners differently, violate the equal protection clause?
The Court held that held that, because Nordlinger lacked standing to assert the federal constitutional right to travel as a basis for heightened equal protection scrutiny of the California assessment system, the appropriate standard of equal protection review was whether the system's difference in treatment between newer and older owners rationally furthered a legitimate state interest. Under the rational basis standard, the system did not violate the equal protection clause, where (1) the California amendment was enacted to achieve the benefits of, and essentially embodied, an "acquisition value" system--under which the assessment of real property was related to the value of the property at the time of acquisition--rather than a system of assessing property at its current value; (2) the California system, which did not discriminate between newer and older owners with respect to either the tax rate or the annual rate of adjustment in assessments, treated newer owners differently with respect to only the basis on which the newer owners' property was initially assessed; (3) there were at least two rational or reasonable considerations that justified denying a new owner the benefits of older owners' lower assessments, as the state (a) had a legitimate interest in local neighborhood preservation, continuity, and stability, and could therefore legitimately decide to structure the tax system to discourage rapid turnovers in ownership, and (b) could legitimately conclude that a new owner did not have the same reliance interest warranting protection against higher taxes as did an existing owner; and (4) the two narrow exemptions from the reassessment requirement also rationally furthered legitimate state interests.
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