Constitutionality of Statutory Classifications
The Uniformity Clause of the Minnesota Constitution states that "taxes shall be uniform upon the same class of subjects...." Minn. Const. Art. X 1.
The Uniformity Clause is no more restrictive on the legislature's power to tax or classify than the Equal Protection Clause of the Fourteenth Amendment of the United States Constitution.
In re McCannel, 301 N.W.2d 910, 916 (Minn. 1980); Kuiters v. County of Freeborn, 430 N.W.2d 461, 462 (Minn. 1988). the same test is used for both analyses. Brainerd Area Civic Ctr. v. Commissioner of Revenue, 499 N.W.2d 468, 472 (Minn. 1993).
The test to determine the constitutionality of statutory classifications requires that:
(1) the distinctions which separate those included within the classification from those excluded must not be manifestly arbitrary or fanciful but must be genuine and substantial, thereby providing a natural and reasonable basis to justify legislation adapted to peculiar conditions and needs;
(2) the classification must be genuine or relevant to the purpose of the law; that is, there must be an evident connection between the distinctive needs peculiar to the class and the prescribed remedy;
(3) the purpose of the statute must be one that the state can legitimately attempt to achieve.
Miller Brewing Co. v. State, 284 N.W.2d 353, 356 (Minn. 1979).
The first prong requires that the classification has a rational basis. Legislative classifications will be upheld as having a rational basis if any facts reasonably support them. Westling, 581 N.W.2d at 821.
The legislation need not contain a statement of purpose. Rio Vista Non-Profit Housing Corp. v. County of Ramsey, 335 N.W.2d 242, 245-46 (Minn. 1983); see also, Hegenes v. State, 328 N.W.2d 719, 721-22 (Minn. 1983) (sustaining a statute by conceiving of a possible legislative basis).
Under the rational basis test, "every presumption is invoked in favor of the constitutionality of an act of the legislature, . . ." Contos v. Herbst, 278 N.W.2d 732, 736 (Minn. 1979).
Furthermore, the party challenging the legislation bears "the burden of proof to show beyond a reasonable doubt that the act conflicts with the uniformity clause of the state constitution." Id.