A classification neither involving fundamental rights nor proceeding along suspect lines cannot run afoul of the Equal Protection Clause if there is a rational relationship between the disparity of treatment and some legitimate governmental purpose. Where ordinary commercial transactions are at issue, rational basis review requires deference to reasonable underlying legislative judgments. Legislatures have especially broad latitude in creating classifications and distinctions in tax statutes.
In accordance with state law, the city formerly assessed sewer-project costs against abutting properties and allowed the owners to make a lump sum payment or pay in installments. The city subsequently changed its assessment method to include issuance of bonds, and forgave future installment payments without providing similar relief to the owners who prepaid their assessments in full.
Was there an equal protection violation where the city had a rational basis for distinguishing between those lot owners who had already paid their share of project costs and those who had not?
The city's tax classification did not involve a fundamental right or suspect classification and only required a rational basis, and the city's administrative concerns justified the distinction between the installment assessments and the prepaid assessments. Maintaining an administrative system to continue collection of installment assessments in addition to the new funding method could have proven to be complex and expensive, and providing refunds for prepaid assessments would have added additional administrative costs of processing and funding the refunds.