Home › Case briefs › Constitutional Law

Armour v. City of Indianapolis

Supreme Court of the United States · 2012 · Constitutional Law

Constitutional LawEqual ProtectionRational Basis ReviewTax ClassificationsEqual Protection Clauserational basistax classificationadministrative convenience

Facts

Indiana's Barrett Law allowed Indianapolis to fund sewer projects by equally apportioning project costs among affected lots, with owners permitted to pay either in a lump sum or by long-term installments. For the Brisbane/Manning sewer project, each affected homeowner was assessed $9,278, and 38 owners paid in full while others chose installment plans. In 2005, the City replaced Barrett Law financing with the STEP program and adopted a resolution forgiving all Barrett Law assessment amounts still due from November 1, 2005 forward. As a result, installment payers no longer had to make future payments, but lump-sum payers received no refunds.

Issue

Whether Indianapolis violated the Equal Protection Clause by forgiving outstanding Barrett Law installment debts while refusing to refund homeowners who had already paid their assessments in full. More specifically, the question was whether the City's distinction between past payers and those with future payment obligations lacked a rational basis.

Rule

When a classification neither involves a fundamental right nor proceeds along suspect lines, it satisfies the Equal Protection Clause if there is any reasonably conceivable state of facts that could provide a rational basis for it. In the tax and local economic context, legislatures receive especially broad latitude, and the challenger bears the burden of negating every conceivable basis that might support the classification; administrative considerations can ordinarily justify a tax-related distinction.

🔒

See the holding & full analysis

Create a free KwikCourt account to unlock the rest of this brief — and practice the case.

The court's holding and reasoning
Doctrine tests, pitfalls & exam hypotheticals
10 practice questions + 4 AI-graded essays on this case

Free sample · practice this case

Test yourself

One of 10 multiple-choice questions for this case. Pick an answer to see why.

Cedar Falls, Iowa, financed alley resurfacing for abutting homes through a special assessment program. Owners could pay $6,000 immediately or over 15 years in monthly installments. Two years later, the city replaced that program with bond financing and forgave all unpaid balances on old assessments, but denied refunds to owners who had already paid in full.

A homeowner who paid the full $6,000 sues under the Equal Protection Clause. No suspect class or fundamental right is involved. Which is the strongest argument that the city's policy is constitutional?

Explanation. Under the majority opinion, a local tax-related classification that involves neither a suspect class nor a fundamental right receives rational basis review. The classification survives if there is any reasonably conceivable state of facts providing a rational basis. Administrative concerns—such as the burden of continuing to collect small installment debts under a legacy system and the added burden of processing refunds—ordinarily can justify a tax-related distinction. The Constitution does not require the city to adopt the fairest or best line, only a rational one.