nordlinger
hahn
argued
february
decided
june
response
rapidly
rising
real
property
taxes
california
voters
approved
statewide
ballot
initiative
proposition
added
article
xiiia
state
constitution
among
things
article
xiiia
embodies
acquisition
value
system
taxation
whereby
property
reassessed
current
appraised
value
upon
new
construction
change
ownership
exemptions
reassessment
provision
exist
two
types
transfers
exchanges
principal
residences
persons
age
transfers
parents
children
time
system
created
dramatic
disparities
taxes
paid
persons
owning
similar
pieces
property
longer
term
owners
pay
lower
taxes
reflecting
historic
property
values
newer
owners
pay
higher
taxes
reflecting
recent
values
faced
disparity
petitioner
former
los
angeles
apartment
renter
recently
purchased
house
los
angeles
county
filed
suit
respondents
county
tax
assessor
claiming
article
xiiia
reassessment
scheme
violates
equal
protection
clause
fourteenth
amendment
county
superior
dismissed
complaint
without
leave
amend
state
appeal
affirmed
held
article
xiiia
assessment
scheme
violate
equal
protection
clause
pp
unless
classification
warrants
form
heightened
review
jeopardizes
exercise
fundamental
right
categorizes
basis
inherently
suspect
characteristic
equal
protection
clause
requires
classification
rationally
legitimate
state
interest
petitioner
may
assert
constitutional
right
travel
basis
heightened
review
article
xiiia
complaint
allege
impeded
traveling
settling
california
purchasing
home
already
lived
los
angeles
prudential
standing
principles
prohibiting
litigant
raising
another
person
legal
rights
may
overlooked
case
since
petitioner
identified
obstacle
preventing
others
wish
travel
settle
california
asserting
claims
shown
special
relationship
whose
rights
seeks
assert
pp
permitting
owners
pay
less
taxes
newer
owners
comparable
property
article
xiiia
assessment
scheme
rationally
furthers
least
two
legitimate
state
interests
first
state
legitimate
interest
local
neighborhood
preservation
continuity
stability
legitimately
decide
structure
tax
system
discourage
rapid
turnover
ownership
homes
businesses
second
state
legitimately
conclude
new
owner
point
purchasing
property
reliance
interest
warranting
protection
higher
taxes
existing
owner
already
saddled
purchase
option
deciding
buy
home
taxes
become
prohibitively
high
pp
allegheny
pittsburgh
coal
co
county
webster
controlling
since
facts
case
precluded
plausible
inference
purpose
tax
assessment
practice
invalidated
achieve
benefits
tax
scheme
pp
article
xiiia
two
reassessment
exemptions
rationally
legitimate
purposes
people
california
reasonably
concluded
older
persons
general
discouraged
exchanging
residences
ones
suitable
changing
family
sizes
incomes
interests
family
neighborhood
continuity
stability
furthered
warrant
exemption
transfers
parents
children
pp
article
xiiia
palpably
arbitrary
must
decline
petitioner
request
invalidate
even
may
appear
improvident
unwise
yet
unlikely
ever
reconsidered
repealed
ordinary
democratic
processes
pp
blackmun
delivered
opinion
rehnquist
white
scalia
kennedy
souter
joined
thomas
joined
part
thomas
filed
opinion
concurring
part
concurring
judgment
post
stevens
filed
dissenting
opinion
post
carlyle
hall
argued
cause
filed
briefs
petitioner
rex
lee
argued
cause
respondents
brief
carter
phillips
mark
hopson
dewitt
clinton
david
muir
albert
ramseyer
briefs
amici
curiae
urging
reversal
filed
building
industry
association
southern
california
et
al
brent
rushforth
bruce
ennis
anthony
epstein
william
rentz
pro
se
briefs
amici
curiae
urging
affirmance
filed
state
california
daniel
lungren
attorney
general
robert
milam
deputy
attorney
general
pete
wilson
governor
california
et
al
michael
bogert
california
taxpayer
association
robert
joe
hull
douglas
kindrick
howard
jarvis
taxpayers
association
et
al
ronald
zumbrun
john
findley
anthony
caso
trevor
grimm
people
advocate
et
al
jayna
kapinski
washington
legal
foundation
et
al
daniel
popeo
john
scully
briefs
amici
curiae
filed
senate
state
california
jeremiah
hallisey
american
planning
association
et
al
william
abbott
marilee
hanson
california
assessors
association
douglas
maloney
allen
haim
international
association
assessing
officers
james
gossett
league
women
voters
california
steven
mccracken
robert
palmer
justice
blackmun
delivered
opinion
california
voters
staged
described
property
tax
revolt
approving
statewide
ballot
initiative
known
proposition
adoption
proposition
served
amend
california
constitution
impose
strict
limits
rate
real
property
taxed
rate
real
property
assessments
increased
year
year
litigation
consider
challenge
equal
protection
clause
fourteenth
amendment
manner
real
property
assessed
california
constitution
proposition
followed
many
years
rapidly
rising
real
property
taxes
california
fiscal
years
revenues
taxes
increased
average
per
year
see
report
senate
commission
property
tax
equity
revenue
california
state
senate
senate
commission
report
response
california
legislature
enacted
several
property
tax
relief
measures
including
cap
tax
rates
boom
state
real
estate
market
persevered
however
median
price
existing
home
doubled
result
tax
levies
continued
rise
sharply
increasing
assessment
values
homeowners
saw
tax
bills
double
triple
period
well
outpacing
growth
income
ability
pay
see
also
oakland
proposition
genesis
consequences
nat
tax
supp
june
property
tax
relief
emerged
major
political
issue
california
one
month
time
tax
relief
advocates
collected
million
signatures
qualify
proposition
june
ballot
see
lefcoe
allison
legal
aspects
proposition
amador
valley
case
election
day
proposition
received
favorable
vote
carried
state
counties
california
secretary
state
statement
vote
supplement
primary
election
june
california
thus
novel
constitutional
amendment
led
property
tax
cut
approximately
billion
first
year
senate
commission
report
california
homeowner
home
enjoyed
immediate
reduction
per
year
property
taxes
enacted
proposition
article
xiiia
california
constitution
caps
real
property
taxes
property
full
cash
value
full
cash
value
defined
assessed
valuation
tax
year
thereafter
appraised
value
real
property
purchased
newly
constructed
change
ownership
occurred
assessment
assessment
may
reflect
year
year
inflationary
rate
exceed
percent
given
year
article
xiiia
also
contains
several
exemptions
reassessment
provision
one
exemption
authorizes
legislature
allow
homeowners
age
sell
principal
residences
carry
previous
assessments
replacement
residences
equal
lesser
value
second
exemption
applies
transfers
principal
residence
million
real
property
parents
children
short
article
xiiia
combines
ceiling
property
tax
rate
cap
annual
increases
assessed
valuations
assessment
limitation
however
subject
exception
new
construction
change
ownership
triggers
reassessment
current
appraised
value
thus
assessment
provisions
article
xiiia
essentially
embody
acquisition
value
system
taxation
rather
commonplace
current
value
taxation
real
property
assessed
values
related
value
property
time
acquired
taxpayer
rather
value
current
real
estate
market
time
system
created
dramatic
disparities
taxes
paid
persons
owning
similar
pieces
property
property
values
california
inflated
far
excess
allowed
cap
increases
assessments
property
newly
constructed
changed
hands
see
senate
commission
report
result
longer
term
property
owners
pay
lower
property
taxes
reflecting
historic
property
values
newer
owners
pay
higher
property
taxes
reflecting
recent
values
reason
proposition
labeled
welcome
stranger
system
newcomer
established
community
welcome
anticipation
contribute
larger
percentage
support
local
government
settled
neighbor
owns
comparable
home
indeed
dollar
terms
differences
tax
burdens
staggering
california
homeowners
owned
homes
since
enactment
proposition
shouldered
billion
residential
property
taxes
paid
homeowners
statewide
property
values
continue
rise
annual
inflationary
cap
disparity
continue
grow
according
amended
complaint
petitioner
stephanie
nordlinger
november
purchased
house
baldwin
hills
neighborhood
los
angeles
county
app
prior
owners
bought
home
two
years
purchase
petitioner
lived
rented
apartment
los
angeles
owned
real
property
california
tr
oral
arg
early
petitioner
received
notice
los
angeles
county
tax
assessor
respondent
informing
home
reassessed
upward
account
change
ownership
app
learned
reassessment
resulted
property
tax
increase
fiscal
year
ibid
petitioner
later
discovered
paying
five
times
taxes
neighbors
owned
comparable
homes
since
within
residential
development
example
one
block
away
house
identical
size
lot
slightly
larger
petitioner
subject
general
tax
levy
based
assessed
valuation
reflected
home
value
plus
per
year
inflation
factor
according
petitioner
total
property
taxes
first
years
home
approach
neighbor
bought
comparable
home
stands
pay
brief
petitioner
general
tax
levied
modest
home
dollars
short
paid
owner
million
malibu
beachfront
home
app
exhausting
administrative
remedies
petitioner
brought
suit
respondents
los
angeles
county
superior
sought
tax
refund
declaration
tax
unconstitutional
amended
complaint
alleged
article
xiiia
created
arbitrary
system
assigns
disparate
real
property
tax
burdens
owners
generally
comparable
similarly
situated
properties
without
regard
use
real
property
taxed
burden
property
places
government
actual
value
property
financial
capability
property
owner
respondents
demurred
minute
order
superior
sustained
demurrer
dismissed
complaint
without
leave
amend
app
pet
cert
california
appeal
affirmed
nordlinger
lynch
cal
rptr
noted
california
already
rejected
constitutional
challenge
disparities
taxation
resulting
article
xiiia
see
amador
valley
joint
union
high
school
dist
state
bd
equalization
cal
characterizing
article
xiiia
acquisition
value
system
appeal
found
survived
equal
protection
review
supported
least
two
rational
bases
first
prevented
property
taxes
reflecting
unduly
inflated
unforeseen
current
values
second
allowed
property
owners
estimate
future
liability
substantial
certainty
cal
app
cal
citing
amador
cal
appeal
also
concluded
recent
decision
allegheny
pittsburgh
coal
county
webster
warrant
different
result
issue
allegheny
pittsburgh
practice
west
virginia
county
tax
assessor
assessing
recently
purchased
property
basis
purchase
price
making
minor
modifications
assessments
property
recently
sold
properties
sold
recently
reassessed
taxed
values
times
properties
sold
determined
unequal
assessment
practice
violated
equal
protection
clause
appeal
distinguished
allegheny
pittsburgh
grounds
california
opted
assessment
method
based
individual
owner
acquisition
cost
marked
contrast
west
virginia
constitution
requires
property
taxed
uniform
rate
statewide
according
estimated
current
market
value
emphasis
original
cal
app
cal
thus
appeal
found
allegheny
prohibit
adopting
acquisition
value
assessment
method
decision
merely
prohibits
arbitrary
enforcement
current
value
assessment
method
emphasis
omitted
appeal
also
rejected
petitioner
argument
effect
article
xiiia
constitutional
right
travel
warranted
heightened
equal
protection
review
determined
right
travel
infringed
article
xiiia
bases
property
owner
assessment
acquisition
value
irrespective
owner
status
california
resident
owner
length
residence
state
benefit
california
residents
deemed
incidental
approach
finally
appeal
found
conclusion
unchanged
exemptions
article
xiiia
ibid
california
denied
review
app
pet
cert
granted
certiorari
ii
equal
protection
clause
fourteenth
amendment
commands
state
shall
deny
person
within
jurisdiction
equal
protection
laws
course
laws
differentiate
fashion
classes
persons
equal
protection
clause
forbid
classifications
simply
keeps
governmental
decisionmakers
treating
differently
persons
relevant
respects
alike
royster
guano
virginia
general
rule
legislatures
presumed
acted
within
constitutional
power
despite
fact
practice
laws
result
inequality
mcgowan
maryland
accordingly
cases
clear
unless
classification
warrants
form
heightened
review
jeopardizes
exercise
fundamental
right
categorizes
basis
inherently
suspect
characteristic
equal
protection
clause
requires
classification
rationally
legitimate
state
interest
see
cleburne
cleburne
living
center
new
orleans
dukes
outset
petitioner
suggests
article
xiiia
qualifies
heightened
scrutiny
infringes
upon
constitutional
right
travel
see
zobel
williams
memorial
hospital
maricopa
county
particular
petitioner
alleges
exemptions
reassessment
transfers
owners
age
transfers
parents
children
run
afoul
right
travel
classify
directly
basis
california
residency
complaint
allege
petitioner
impeded
traveling
settling
california
noted
prior
purchasing
home
petitioner
lived
apartment
los
angeles
prudential
standing
principles
impose
general
prohibition
litigant
raising
another
person
legal
rights
allen
wright
see
also
moose
lodge
irvis
petitioner
identified
obstacle
preventing
others
wish
travel
settle
california
asserting
claims
behalf
shown
special
relationship
whose
rights
seeks
assert
might
overlook
prudential
limitation
caplin
drysdale
chartered
accordingly
petitioner
may
assert
constitutional
right
travel
basis
heightened
review
appropriate
standard
review
whether
difference
treatment
newer
older
owners
rationally
furthers
legitimate
state
interest
general
equal
protection
clause
satisfied
long
plausible
policy
reason
classification
see
railroad
retirement
bd
fritz
legislative
facts
classification
apparently
based
rationally
may
considered
true
governmental
decisionmaker
see
minnesota
clover
leaf
creamery
relationship
classification
goal
attenuated
render
distinction
arbitrary
irrational
see
cleburne
cleburne
living
center
standard
especially
deferential
context
classifications
made
complex
tax
laws
structuring
internal
taxation
schemes
large
leeway
making
classifications
drawing
lines
judgment
produce
reasonable
systems
taxation
williams
vermont
quoting
lehnhausen
lake
shore
auto
parts
see
also
regan
taxation
representation
legislatures
especially
broad
latitude
creating
classifications
distinctions
tax
statutes
newer
older
owners
article
xiiia
discriminate
respect
either
tax
rate
annual
rate
adjustment
assessments
newer
older
owners
alike
benefit
short
long
run
protections
tax
rate
ceiling
increase
assessment
value
per
year
new
owners
old
owners
treated
differently
respect
one
factor
basis
property
initially
assessed
petitioner
true
complaint
state
denied
new
owner
benefit
assessment
value
neighbors
older
owners
enjoy
difficulty
ascertaining
least
two
rational
reasonable
considerations
difference
policy
justify
denying
petitioner
benefits
neighbors
lower
assessments
first
state
legitimate
interest
local
neighborhood
preservation
continuity
stability
village
euclid
ambler
realty
state
therefore
legitimately
decide
structure
tax
system
discourage
rapid
turnover
ownership
homes
businesses
example
order
inhibit
displacement
lower
income
families
forces
gentrification
established
businesses
newer
chain
operations
permitting
older
owners
pay
progressively
less
taxes
new
owners
comparable
property
article
xiiia
assessment
scheme
rationally
furthers
interest
second
state
legitimately
conclude
new
owner
time
acquiring
property
reliance
interest
warranting
protection
higher
taxes
existing
owner
state
may
deny
new
owner
point
purchase
right
lock
assessed
value
enjoyed
existing
owner
comparable
property
existing
owner
rationally
may
thought
vested
expectations
property
home
deserving
protection
anticipatory
expectations
new
owner
point
purchase
new
owner
full
information
scope
future
tax
liability
acquiring
property
thinks
future
tax
burden
demanding
decide
complete
purchase
contrast
existing
owner
already
saddled
purchase
option
deciding
buy
home
taxes
become
prohibitively
high
meet
tax
obligations
might
forced
sell
home
divert
income
away
purchase
food
clothing
necessities
short
state
may
decide
worse
owned
lost
never
owned
previously
acknowledged
classifications
serving
protect
legitimate
expectation
reliance
interests
deny
equal
protection
laws
protection
reasonable
reliance
interests
legitimate
governmental
objective
provides
exceedingly
persuasive
justification
heckler
mathews
internal
quotations
example
kadrmas
dickinson
public
schools
determined
prohibition
user
fees
bus
service
reorganized
school
districts
nonreorganized
school
districts
violate
equal
protection
clause
legislature
conceivably
believed
policy
serve
legitimate
purpose
fulfilling
reasonable
expectations
residing
districts
free
busing
arrangements
imposed
reorganization
plans
similarly
railroad
retirement
bd
fritz
supra
determined
denial
dual
windfall
retirement
benefits
railroad
workers
others
violate
equal
protection
clause
congress
properly
conclude
persons
actually
acquired
statutory
entitlement
windfall
benefits
still
employed
railroad
industry
greater
equitable
claim
benefits
members
appellee
class
longer
railroad
employment
became
eligible
dual
benefits
finally
new
orleans
dukes
determined
ordinance
banning
certain
street
vendor
operations
grandfathering
existing
vendors
operation
eight
years
violate
equal
protection
clause
city
reasonably
decide
newer
businesses
less
likely
built
substantial
reliance
interests
continued
operation
petitioner
argues
article
xiiia
distinguished
tax
assessment
practice
found
violate
equal
protection
clause
allegheny
pittsburgh
like
article
xiiia
practice
issue
allegheny
pittsburgh
resulted
dramatic
disparities
taxation
properties
comparable
value
obvious
critical
factual
difference
case
allegheny
pittsburgh
absence
indication
allegheny
pittsburgh
policies
underlying
taxation
scheme
conceivably
purpose
webster
county
tax
assessor
unequal
assessment
scheme
first
place
webster
county
argued
assessment
scheme
rationally
related
purpose
assessing
properties
true
current
value
emphasis
added
moreover
west
virginia
constitution
laws
provide
property
kind
held
petitioners
shall
taxed
rate
uniform
throughout
state
according
estimated
market
value
found
suggestion
state
may
adopted
different
system
practice
specified
statute
sure
equal
protection
clause
demand
purposes
rational
basis
review
legislature
governing
decisionmaker
actually
articulate
time
purpose
rationale
supporting
classification
railroad
retirement
bd
fritz
see
also
mcdonald
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past
decades
california
property
owners
enjoyed
extraordinary
prosperity
state
population
mushroomed
value
real
estate
alone
total
assessed
value
california
property
subject
property
taxation
increased
tenfold
simply
put
invested
california
real
estate
among
fortunate
capitalists
world
proposition
provided
successful
investors
tremendous
windfall
created
severe
inequities
california
property
tax
scheme
property
owners
hereinafter
squires
guaranteed
long
retain
property
improve
taxes
increase
given
year
direct
result
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later
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must
pay
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share
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taxes
specific
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prompted
petitioner
challenge
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property
tax
bill
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times
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homeowners
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pet
cert
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proposition
controls
taxation
commercial
property
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result
proposition
squires
residences
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total
taxes
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homeowners
report
senate
commission
property
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owner
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million
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property
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proposition
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property
tax
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inequity
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young
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value
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parents
date
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policy
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tax
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ante
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property
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standard
review
equal
protection
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tax
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lehnhausen
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shore
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standard
review
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county
webster
hooper
bernalillo
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assessor
williams
vermont
metropolitan
life
ins
ward
cf
zobel
williams
three
terms
ago
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ntentional
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protection
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fourteenth
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secure
every
person
within
state
jurisdiction
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protection
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county
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like
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county
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equal
protection
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indeed
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statewide
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broad
power
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equal
protection
law
kentucky
stated
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burden
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board
tax
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kansas
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lehnhausen
lake
shore
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majestic
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purchased
worth
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placed
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two
properties
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sale
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price
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property
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property
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purchase
price
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stores
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bowers
ii
contemporary
equal
protection
doctrine
test
whether
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whether
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interest
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protection
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protection
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law
nondiscriminatory
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within
class
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rinaldi
yeager
williams
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rationally
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fit
disparate
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legislative
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review
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recognizing
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substantially
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mathematical
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orleans
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cases
underinclusiveness
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legislative
distinction
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posited
state
interest
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jimenez
weinberger
cursory
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aspects
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standard
review
first
state
interest
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california
interest
local
neighborhood
preservation
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ante
citing
village
euclid
ambler
realty
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question
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ing
displacement
lower
income
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legitimate
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interest
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whether
disparate
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purchasers
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goal
offers
analysis
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owners
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new
owners
comparable
property
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rationally
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disagree
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sweeps
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interest
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early
purchasers
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fixed
limited
incomes
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pay
higher
taxes
still
maintain
homes
california
enacted
special
legislation
respond
plight
concerns
provide
adequate
justification
proposition
statewide
tax
windfall
property
owners
descendants
rational
means
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tax
exemption
taxpayers
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smith
rational
means
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particular
taxpayer
named
smith
demonstrated
difficulty
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tax
bill
even
within
densely
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angeles
county
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half
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value
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tax
roll
app
said
legitimate
state
interest
preserving
neighborhood
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rationally
furthered
tax
benefits
owners
commercial
industrial
vacant
nonresidential
properties
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legitimate
state
interest
protecting
relatively
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number
economically
vulnerable
families
rationally
furthered
tax
windfall
property
owners
california
conclusion
unsound
lack
numerical
fit
posited
state
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also
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logical
fit
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means
although
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may
valid
interest
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neighborhoods
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displacement
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families
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transfer
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land
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buildings
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uses
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proposition
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ambler
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treats
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owners
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interest
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tax
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persons
purchased
property
rationally
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accomplish
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severe
inequalities
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justified
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state
interest
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interests
earlier
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protection
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case
purchased
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property
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purchasers
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owner
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home
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owner
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purchase
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owner
full
information
scope
future
tax
liability
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property
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future
tax
burden
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existing
owner
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purchase
option
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buy
home
taxes
become
prohibitively
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ante
distilled
essence
seems
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earlier
purchasers
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purpose
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proposition
justified
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reliance
interests
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treat
similarly
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persons
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date
joined
class
property
owners
today
thought
proposition
far
controversial
zobel
williams
ruled
alaska
program
distributing
cash
dividends
basis
recipient
years
residency
state
violated
equal
protection
clause
wrote
make
amount
cash
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length
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preclude
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tuition
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access
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civil
service
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contracts
length
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taxes
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length
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reasoning
open
door
state
apportionment
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length
residency
permit
divide
citizens
expanding
numbers
permanent
classes
result
clearly
impermissible
emphasis
added
footnotes
omitted
decisions
demonstrate
selective
provision
benefits
based
timing
one
membership
class
whether
class
class
residents
class
property
owners
rarely
legitimate
state
interest
similarly
situated
neighbors
equal
right
share
benefits
local
government
obviously
unconstitutional
provide
one
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plainly
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require
one
pay
five
times
much
property
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services
opinion
severe
inequalities
created
proposition
arbitrary
unreasonable
rationally
legitimate
state
interest
accordingly
respectfully
dissent
glennon
taxation
equal
protection
period
property
values
hawaii
rose
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washington
approximately
new
york
approximately
ibid
citing
dept
commerce
bureau
census
taxable
property
values
table
dept
commerce
bureau
census
taxable
property
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price
ratios
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proposition
codified
article
xiiia
california
constitution
convenience
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however
refer
colloquial
name
notes
ante
petitioner
contends
proposition
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right
travel
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standard
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gross
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review
cf
hooper
bernalillo
county
assessor
zobel
williams
herod
ordering
death
male
children
born
particular
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one
day
bring
downfall
employed
overinclusive
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wartime
treatment
american
citizens
japanese
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imposed
burdens
upon
large
class
individuals
believed
disloyal
tussman
tenbroek
equal
protection
laws
pointed
commission
report
california
addressed
specific
problem
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legislation
state
established
two
programs
senior
citizens
property
tax
assistance
provides
refunds
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property
taxes
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income
homeowners
age
rationale
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proposition
even
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apply
vacant
property
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proposition
discourages
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means
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development
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matter
socially
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squires
commercial
property
wholly
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rational
state
interest
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entrepreneurs
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discourage
otherwise
desirable
transfers
property
free
economy
entry
new
competitors
encouraged
arbitrarily
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unfavorable
tax
treatment
brief
california
assessors
association
amicus
curiae
ambiguous
character
interest
illustrated
options
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married
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owns
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lived
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taxes
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proposition
tend
motivate
sale
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family
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home
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rental
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income
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proposition
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wasteful
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housing
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justified
state
interest
protecting
property
owners
taxation
unrealized
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california
relied
similar
state
interest
see
amador
valley
joint
union
high
school
dist
state
bd
equalization
argument
closely
related
reasoning
concerning
neighborhood
preservation
respondent
claims
state
interest
preventing
situation
skyrocketing
real
estate
prices
driv
property
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taxpayers
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descendants
simply
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vulnerable
taxpayers
sympathetic
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owner
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fact
early
purchasers
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property
increase
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drawing
analysis
california
contends
inequities
created
proposition
also
justified
state
interest
permitting
taxpayer
make
careful
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predictions
future
tax
liability
amador
valley
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agree
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tax
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whether
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proposition
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