Stafford Higgins Indus., Inc. v. City of Norwalk
In Stafford Higgins Indus., Inc. v. City of Norwalk, 245 Conn. 551, 715 A.2d 46 (Conn. 1998), a taxpayer challenged the constitutionality of a state statute allowing a municipality to stay the implementation of the municipality's decennial revaluation for up to two years and the City of Norwalk's action in refusing to implement its revaluation.
The case revolved around a 1994 action by the city of Norwalk, done pursuant to the challenged statute, twice staying the implementation of the city's 1993 decennial revaluation, which had the effect of retaining the real property valuations of 1983 for the grand lists of 1993 through 1996. Id. at 48.
Plaintiff alleged that the city took this action because the revaluation would have resulted in significantly shifting the property tax burden from single-family residences to commercial properties in accordance with the increases of the fair market value of the latter property. Id. at 56.
The court applied the rational basis test set out in Nordlinger and found the city's action to be constitutional. According to the court, the rational basis for the city's action "was to implement, in an orderly manner, the changes to the existing property taxation system anticipated to be enacted in the next legislative session as a result of the recommendations of the property tax reform commission." Id.
The court also agreed with the trial court's finding that the purpose of the city's action was "not to burden commercial property owners but to alleviate the burden on single-family homeowners, that is, 'in spite of', not 'because of' the burden which would be assumed by nonsingle-family property owners." Id.
Since the legislation had a rational basis and the taxpayer had not demonstrated any discrimination - as is the case with the legislation at issue in the current appeal - the court upheld the constitutionality of the statute. Id. at 56-57.