Town of Secaucus v. Hudson County Bd. Of Taxation

In Town of Secaucus v. Hudson County Bd. Of Taxation, 133 N.J. 482, 492, 628 A.2d 288 (1993), cert. denied sub nom. City of Bayonne v. Town of Secaucus, 510 U.S. 1110, 114 S. Ct. 1050, 127 L. Ed. 2d 372 (1994), that city challenged a statute that originally exempted any municipality that maintained its own vocational education system from contributing to that portion of the county tax used to maintain the county's vocational school. 133 N.J. at 487-89, 628 A.2d 288. However, by amendment, the benefit was limited to municipalities in a first class county with a population of no more than 700,000, making Hudson County municipalities alone eligible, and further limited the benefit to municipalities whose vocational program had been in existence for at least twenty years--a longevity requirement. As a result, only Bayonne could qualify. Id. The Court found "two possible interpretations of the statute that on their face reveal a legitimate legislative purpose." Id. at 495, 628 A.2d 288. One was "to address the problem of double contributions by municipalities that have their own vocational programs. . . ." The other "may be to promote the development of local, high quality vocational educational programs within densely--populated communities." Id. The Court found it "difficult to see" how the population-density and longevity requirements rationally served either purpose because the prospect of double contributions was faced by "at least twenty municipalities within the state, and at least one other municipality within Hudson County . . ." and because "if the goal of the statute is to encourage the development of high-quality vocational educational programs within densely-populated municipalities, . . . to exclude municipalities either in the most-populous counties, i.e., Essex and Bergen, or in less but densely-populated counties like Union and Middlesex, does not seem reasonable." Id. at 495-96, 628 A.2d 288. To accept the classifications contained in the statute as having a rational basis, one must imagine that the Legislature had some reasonable ground for encouraging the development of local vocational programs only in the most-densely-populated county in the state with a total population below 700,000, and that the Legislature had reasonable grounds for concluding that only those programs in existence for at least twenty years were of sufficient quality to be worthy of financial encouragement through tax relief. Those conclusions seem to us to stretch credulity beyond reasonable limits. Id. at 498, 628 A.2d 288.