armour et al city indianapolis indiana et argued february decided june decades indianapolis city funded sewer projects using indiana barrett law permitted cities apportion public improvement project costs equally among abutting lots system city create initial assessment dividing total estimated cost number lots making necessary adjustments upon project completion city issue final assessment lot owners elect pay assessment lump sum time installments city completed sanitary sewers project sent affected homeowners formal notice payment obligations affected homeowners elected pay lump sum following year city abandoned barrett law financing adopted septic tank elimination program step financed projects part bonds thereby lowering individual owner costs implementing step city board public works enacted resolution forgiving assessment amounts still owed pursuant barrett law financing homeowners paid project lump sum received refund homeowners elected pay installments obligation make payments homeowners paid lump sum asked city refund city denied request homeowners brought suit indiana state claiming relevant part city refusal violated federal equal protection clause trial granted summary judgment homeowners state appeals affirmed indiana reversed holding city distinction already paid rationally related legitimate interests reducing administrative costs providing financial hardship relief homeowners transitioning barrett law system step preserving limited resources held city rational basis distinction thus violate equal protection clause pp city classification involve fundamental right suspect classification see heller doe subject matter local economic social commercial see carolene products tax classification see regan taxation representation one claims city discriminated commerce new residents cf hooper bernalillo county assessor hence city distinction violate equal protection clause long reasonably conceivable state facts provide rational basis classification fcc beach communications one attacking classification negative every conceivable basis might support heller supra pp administrative concerns ordinarily justify distinction see carmichael southern coal coke city decision stop collecting outstanding barrett law debts finds rational support city administrative concerns city switched step system decision continue barrett law debt collection proved complex expensive meant maintaining administrative system years come collect debts arising different construction projects built course decade involving monthly payments low per household possible need maintain credibility tracking defaulting debtors bringing legal action rationality city distinction draws support nature choices confronted added refunds forgiveness meant adding administrative costs namely cost processing refunds limiting refunds homeowners led complaints unfairness expanding refunds apparently thousands barrett law project homeowners involved even greater administrative burden finally rationality distinction draws support fact line city drew distinguishing past payments future obligations well known law see pp petitioners contrary arguments unpersuasive whether financial hardship factor supporting rationality need considered since city administrative concerns sufficient show rational basis distinction petitioners propose forgiveness systems argue superior city system constitution requires line actually drawn city rational petitioners argue administrative considerations alone justify tax distinction lest city justify unfair system insubstantial administrative considerations rational city draw line avoided administrative burden collecting paying small sums years come petitioners shown administrative concerns insubstantial justify classification finally petitioners argue precedent makes difficult city show rational basis cases refer involve discrimination based residence length residence one exception allegheny pittsburgh coal commission webster distinguishable pp affirmed breyer delivered opinion kennedy thomas ginsburg sotomayor kagan joined roberts filed dissenting opinion scalia alito joined opinion notice opinion subject formal revision publication preliminary print reports readers requested notify reporter decisions washington typographical formal errors order corrections may made preliminary print goes press christine armour et petitioners city indianapolis indiana et al writ certiorari indiana june justice breyer delivered opinion many years indiana statute barrett law authorized indiana cities impose upon benefited lot owners cost sewer improvement projects law also permitted lot owners pay either immediately form lump sum time installments city indianapolis city adopted new assessment payment method step plan forgave barrett law installments lot owners yet paid group lot owners already paid entire barrett law assessment lump sum believe city provided equivalent refunds must decide whether city refusal unconstitutionally discriminates violation equal protection clause amdt hold city rational basis distinguishing lot owners already paid share project costs conclude equal protection violation beginning indiana barrett law permitted cities pay public improvements sewage projects apportion ing costs project equally among abutting lands lots ind code see town council new harmony parker ind project beneficiaries pay costs city built barrett law project city public works board create initial assessment dividing estimated total cost sewage works total number lots might adjust individual assessment downward lot benefit less others upon completion project board issue final assessment law permitted lot owners pay assessment either single lump sum time installment payments interest city collect installment payments manner taxes law authorized installment plans fully paid assessment constitute lien property permitting city initiate foreclosure proceedings case default several decades indianapolis used barrett law system fund sewer projects see conley brummit ind app banc city adopted new system called septic tank elimination program step financed projects part bonds thereby lowering individual lot owners costs time city constructed barrett law projects app pet cert told lot owners still owed money respect projects see reply brief petitioners citing city response plaintiff brief damages record cox indianapolis sd doc exh respect installment payments yet fallen due respect owed money default reply brief petitioners case concerns one barrett law projects namely sanitary sewers project project began connected homes city sewage system construction completed indianapolis board public works held assessment hearing june july board sent affected homeowners formal notice payment obligations notice made clear homeowner pay entire assessment per property lump sum installments include interest annual rate installment plan payments amount per month years per month years per month years event homeowners chose pay front chose plan chose plan chose plan first year homeowner paid amount due upfront plan plan plan app pet cert next year however city decided abandon barrett law method financing thought barrett law payments become burdensome many homeowners pay discouraging changes less healthy septic tanks healthier sewer systems see example homes helped project cost valued app city new step method financing charge connecting lot owner flat fee make difference floating bonds eventually paid lot owners citywide see app pet cert october city enacted ordinance implementing decision december city board public works enacted resolution resolution part transition forgive assessment amounts established pursuant barrett law funding municipal sewer programs due owing date november forward app emphasis added preamble resolution said barrett law may present financial hardships many middle lower income participants need sanitary sewer service lieu failing septic systems pointed city transitioning new step method financing said step method based upon financial model considered current assessments made participants active barrett law projects well future projects upshot still owed barrett law assessments make payments already paid assessments receive refunds meant homeowners paid full manning project assessment lump sum preceding year receive refund homeowners elected pay assessment installments paid total obligation make payments february homeowners paid full project assessment asked city partial refund amount equal smallest forgiven installment debt apparently city denied request part efunding payments made project area portion payments establish precedent unfair inequitable treatment property owners also paid barrett law assessments november cutoff date might seem arbitrary essential city establish date move forward new funding approach project homeowners brought lawsuit indiana state seeking refund claimed relevant part city refusal provide refunds time city forgave outstanding project debts homeowners violated federal constitution equal protection clause amdt see also rev stat trial granted summary judgment favor state appeals affirmed judgment indiana reversed view city distinction already paid barrett law assessments rationally related legitimate interests reducing administrative costs providing relief property owners experiencing financial hardship establishing clear transition barrett law step preserving limited resources app pet cert granted certiorari consider equal protection question affirm indiana ii long city distinction rational basis distinction violate equal protection clause long held classification neither involving fundamental rights proceeding along suspect lines run afoul equal protection clause rational relationship disparity treatment legitimate governmental purpose heller doe cf gulf ellis made clear analogous contexts ordinary commercial transactions issue rational basis review requires deference reasonable underlying legislative judgments carolene products due process see also new orleans dukes per curiam equal protection repeatedly pointed egislatures especially broad latitude creating classifications distinctions tax statutes regan taxation representation see also fitzgerald racing assn central iowa nordlinger hahn lehnhausen lake shore auto parts madden kentucky citizens telephone grand rapids fuller indianapolis classification involves neither fundamental right suspect classification subject matter local economic social commercial tax classification one claims indianapolis discriminated commerce new residents cf hooper bernalillo county assessor williams vermont metropolitan life ins ward zobel williams hence case falls directly within scope precedents holding law constitutionally valid plausible policy reason classification legislative facts classification apparently based rationally may considered true governmental decisionmaker relationship classification goal attenuated render distinction arbitrary irrational nordlinger supra citations omitted falls within scope precedents holding plausible reason reasonably conceivable state facts provide rational basis classification fcc beach communications see also lindsley natural carbonic gas moreover analogous precedent warns us pronounc classification unconstitutional unless light facts made known generally assumed character preclude assumption rests upon rational basis within knowledge experience legislators carolene products supra due process claim classification presumed constitutional burden one attacking legislative arrangement negative every conceivable basis might support heller supra quoting lehnhausen supra view indianapolis classification rational basis ordinarily administrative considerations justify distinction see carmichael southern coal coke tax exemption businesses fewer eight employees rational light dministrative convenience expense involved see also lehnhausen supra comparing administrative cost taxing corporations versus individuals madden supra comparing administrative cost taxing deposits local banks versus elsewhere city decision stop collecting outstanding barrett law debts finds rational support related administrative concerns city decided switch step system change continue barrett law collection proved complex expensive meant maintaining administrative system years come collect debts arising different construction projects built course decade involving monthly payments low per household possible need maintain credibility tracking defaulting debtors bringing legal action city example maintain barrett law operation within city controller office keep files old small debts city official says possibly spend hundreds thousands dollars keeping computerized systems current see brief international management association et al amici curiae citing affidavit charles white record cox doc unlike collection system prior abandonment city added new barrett law debtors fact means spread fixed administrative costs collection number debtors thereby continuously increasing cost collection consistent facts director city department public works later explained city decided forgive outstanding debt part administrative costs service process remaining balances barrett law accounts long past transition step program benefit taxpayers defeat purpose transition app four members city board public works said see affidavit gregory taylor record cox doc affidavit kipper tew ibid doc affidavit susan schalk ibid doc affidavit roger brown ibid doc rationality city distinction draws support nature choices confronted added refunds forgiveness meant adding yet administrative costs namely cost processing refunds time tried limit city costs lost revenues limiting forgiveness refund rules homeowners alone led involved barrett law projects justifiably complained unfairness yet granted refunds well providing forgiveness involved barrett law projects projects open projects involved even greater administrative burden city cut checks post roberts dissenting without taking funding programs finding additional revenue instead city tried keep amount revenue lost constant rational goal spread evenly among apparently thousands homeowners involved barrett laws projects result yet smaller individual payments even likely small justify administrative expense finally rationality distinction draws support fact line city drew distinguishing past payments future obligations line well known law sometimes line takes form amnesty program involving say mortgage payments taxes parking tickets supp iv federal income tax provision allowing homeowners omit gross income newly forgiven home mortgage debt martin tax amnesty program whereby state newly forgave penalties liabilities taxpayer satisfied debt horn chicago city parking ticket amnesty program whereby outstanding tickets newly settled fraction amount specified kind line consistent distinction law often makes actions previously taken yet come petitioners contrary arguments sufficient change conclusion petitioners point indiana also listed different consideration namely financial hardship one factors supporting rationality app pet cert refer city resolution said barrett law may present financial hardships many middle lower income participants need sanitary sewer service lieu failing septic systems app argue tax distinction us necessarily favor homeowners need consider argument however administrative considerations mentioned sufficient show rational basis city distinction indiana wrote city classification rationally related part legitimate interests reducing administrative costs app pet cert emphasis added record city proceedings consistent determination see app developing transition city considered current assessments made participants active barrett law projects event legislature need actually articulate time purpose rationale supporting classification nordlinger see also fitzgerald similar rather burden one attacking legislative arrangement negative every conceivable basis might support madden see heller lehnhausen see also allied stores ohio bowers upholding state tax classification resting upon state facts reasonably conceived creating rational distinction petitioners negative indiana first listed justification namely administrative concerns discussed petitioners go propose various forgiveness systems included refunds least already paid full argue systems superior system city chose discussed possible systems earlier supra advantages disadvantages even petitioners found superior system constitution require city draw perfect line even draw line superior line might drawn requires line actually drawn rational line reasons set forth part supra believe line city drew rational petitioners argue administrative considerations alone justify tax distinction lest city arbitrarily allocate taxes among citizens forgiving many similarly situated citizens ground cheaper easier collect taxes people many brief petitioners petitioners right administrative considerations justify unfair system administrative considerations never justify tax differences always question whether reducing expenses particular circumstances provides rational basis justifying tax difference question case light facts made known generally assumed carolene products reasonable believe graft refund system onto city forgiveness decision example imposed administrative burden collecting paying small sums say per month years said supra rational city draw line avoids burden petitioners ones attacking legislative arrangement burden showing circumstances otherwise administrative burden insubstantial justify classification done finally petitioners point precedent view makes difficult said city show rational basis one exception however cases refer involve discrimination based residence length residence hooper bernalillo county assessor state tax preference distinguishing resident veterans williams vermont state use tax burdened car buyers moved metropolitan life ins ward state law taxed insurance companies higher rate companies zobel williams state dividend distribution system favored residents circumstances present exception consists allegheny pittsburgh coal commission webster took account state constitution related laws required equal valuation equally valuable property considered constitutionality county tax assessor practice period many years determining property values time property last sale practice meant highly unequal valuations two identical properties sold years decades apart first found assessor practice rationally related county avowed purpose assessing properties equally true current value intentional systemic discrepancies practice created noted light state constitution related laws requiring equal valuation rational basis practice therefore held assessor discriminatory policy violated federal constitution insistence upon equal protection law petitioners argue city refusal add refunds forgiveness decision similar constitutes refusal apply equally indiana state law says costs barrett law project shall equally apportioned ind code words petitioners say even city decision might otherwise related rational purpose state law allegheny makes rare case facts preclude rational basis city decision comply state mandate equality allegheny however involved clear state law requirement clearly dramatically violated indeed described allegheny rare case facts precluded alternative reading state law thus alternative rational basis nordlinger city followed state law apportioning cost barrett law projects equally state law says nothing forgiveness design forgiveness program whether rational distinctions permitted adopt petitioners view risk transforming ordinary violations ordinary state tax law violations federal constitution reasons conclude city violated federal equal protection clause indiana similar determination affirmed roberts dissenting christine armour et petitioners city indianapolis indiana et al writ certiorari indiana june chief justice roberts justice scalia justice alito join dissenting years ago released succinct unanimous opinion striking property tax scheme west virginia ground clearly violated equal protection clause allegheny pittsburgh coal commission webster allegheny pittsburgh held county failed comport equal protection requirements assessed property taxes primarily basis purchase price appropriate adjustments time result new property owners assessed roughly times rate owned property longer found gross disparit tax levels justified state system demanded taxation equal uniform va art case affirmed proposition equal protection clause violated state action deprives citizen even rough equality tax treatment state law specifically provides affected taxpayers category tax purposes see hillsborough cromwell equal protection clause protects individual state action selects discriminatory treatment subjecting taxes imposed others class case sanitary sewers project allowed property owners homes hooked city indianapolis sewer system state barrett law law requires sewer costs primarily apportioned equally among abutting lands lots ind code case cost came property owner property owners petitioners paid full front others elected option paying installments shortly city switched new financing system decided forgive debts paying installment plan city refused however refund portion payments made identically situated neighbors already paid full amount due result petitioners paid city half neighbors paid less improvement little another quarter paid less petitioners thus paid times much sewer neighbors seeking justify gross disparity city explained presented three choices first continued collect installment plan payments yet settled debts old system second forgiven debts given equivalent refunds made lump sum payments front third forgiven future payments refunded payments already made first two choices benefit complying state law treating indianapolis citizens equally comporting constitution city chose third option city believe sufficient justify system effectively charge petitioners times neighbors service state law promised equal treatment two things desire avoid administrative hassle fiscal challeng giving back money wanted keep brief respondents agree reasons pass constitutional muster even rational basis review city argues either options transitioning away barrett law immensely difficult administrative standpoint accepts rationale observing rdinarily administrative considerations justify distinction ante cases cites however stand proposition legislature crafting tax scheme may take administrative concerns consideration creating classes taxable entities may taxed differently see lehnhausen lake shore auto parts state may draw lines treat one class individuals entities differently others madden kentucky referring broad discretion classification possessed legislature carmichael southern coal coke discussing permissible considerations legislature establishing tax scheme however indiana tax scheme explicitly provides costs primarily apportioned equally among abutting lands lots ind code emphasis added legislature therefore decreed abutting landowners within class never held administrative burdens justify grossly disparate tax treatment state provided treated alike indeed allegheny pittsburgh county argued unequal assessments based dministrative cost concerns avail brief respondent reason rejected argument obvious equal protection clause provide state shall deny person within jurisdiction equal protection laws unless much bother even inclined decide administrative burdens alone may sometimes justify grossly disparate treatment members class hardly case city claims issue refunds process difficult requiring pore records old projects determine homeowners overpaid much brief respondents holding city must refund petitioners overpayments mean refund overpayments every barrett law project equal protection clause concerned gross disparity taxing project initiated shortly barrett law transition disparity petitioners paid comparison installment plan neighbors dramatic respect example project initiated years earlier projects even installment plan payers largely satisfied debts resulting far less significant disparities extent ruling petitioners require issuing refunds others overpaid barrett law think city workers task city fact already produced records showing exactly much payer overpaid every active barrett law project penny record cox indianapolis sd ind doc exh city employees need therefore cut checks mail certainly job need involve complicated procedure describes attempt bolster administrative convenience argument view city apparently continue accept monthly payments installment plan homeowners order gradually repay money owes paid lump sum ante approach never dreamt city see brief respondents setting city three basic transition options none involved gradual refund scheme suggests city administrative convenience argument one law comfortable compares city decision forgive installment balances sort parking ticket mortgage payment amnesty programs currently abound ante analogy misplaced amnesty programs designed entice unlikely ever pay debts come forward pay least portion owe administrative convenience alone justifies schemes sense schemes help remedy payment inequities prompting pay nothing pay least fair share said city system willing concede administrative considerations justify unfair system city arbitrarily allocate taxes among citizens forgiving many others ground cheaper easier collect taxes people many ante cold comfort quoted language accurately describe case sure reach wisely embrace city alternative argument unequal tax burden justified fiscally challenging issue refunds brief respondents fiscally challenging gives euphemism bad name city claim already spent petitioners money hardly worth response city recognizes much admits provide refunds petitioners arrang ing payments law sources one evade returning money rightful owner simple expedient spending fiscal challenge justification seems particularly inappropriate case city annual budget approximately million admits cost refunding petitioners money approximately adopted budget consolidated city indianapolis marion county tr oral arg equally unconvincing attempt distinguish allegheny pittsburgh claims case different involved clear state law requirement clearly dramatically violated ante nothing less stake indiana law requires costs sewer projects apportioned equally among abutting lands ind code city instead apportioned costs manning project petitioners paid times much neighbors worse still done order avoid administrative hassle save bit money paraphrase man seasons profits city nothing give treating citizens equally whole world see bolt man seasons act ii vintage ed precedents ask much government area rough equality tax treatment allegheny pittsburgh reminds us allegheny pittsburgh rare case ante give great leeway taxing authorities area good sufficient reasons every generation case comes along needs say enough enough equal protection clause retain force context allegheny pittsburgh case one indiana law promised neighboring homeowners treated equally came paying sewer city ended charging homeowners times charged neighbors equal protection violation plain accordingly reverse decision indiana respectfully dissent decision otherwise