Nordlinger v. Hahn

In Nordlinger v. Hahn, 505 U.S. 1 (1992), the United States Supreme Court upheld Proposition 13, California's so-called "welcome stranger" real estate tax system. This system created widely disparate tax burdens among owners of similar pieces of property: longer term property owners paid lower property taxes reflecting historic property values, while newer owners of comparable properties paid higher property taxes reflecting more recent acquisition values. Applying the rational basis test, the Court concluded that Proposition 13 complied with the Equal Protection Clause: "The appropriate standard of review is whether the difference in treatment between newer and older owners rationally furthers a legitimate state interest. In general, the Equal Protection Clause is satisfied so long as there is a plausible policy reason for the classification, the legislative facts on which the classification is apparently based rationally may have been considered to be true by the governmental decisionmaker, and the relationship of the classification to its goal is not so attenuated as to render the distinction arbitrary or irrational. This standard is especially deferential in the context of classifications made by complex tax laws. In structuring internal taxation schemes the States have large leeway in making classifications and drawing lines which in their judgment produce reasonable systems of taxation." Id. at 11.