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` OCTOBER TERM, 2011
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`Syllabus
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`1
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` NOTE: Where it is feasible, a syllabus (headnote) will be released, as is
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` being done in connection with this case, at the time the opinion is issued.
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` The syllabus constitutes no part of the opinion of the Court but has been
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` prepared by the Reporter of Decisions for the convenience of the reader.
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` See United States v. Detroit Timber & Lumber Co., 200 U. S. 321, 337.
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`SUPREME COURT OF THE UNITED STATES
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` Syllabus
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` ARMOUR ET AL. v. CITY OF INDIANAPOLIS, INDIANA,
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`ET AL.
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`CERTIORARI TO THE SUPREME COURT OF INDIANA
`No. 11–161. Argued February 29, 2012—Decided June 4, 2012
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`For decades, Indianapolis (City) funded sewer projects using Indiana’s
`Barrett Law, which permitted cities to apportion a public improve-
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`ment project’s costs equally among all abutting lots. Under that sys-
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`tem, a city would create an initial assessment, dividing the total es-
`timated cost by the number of lots and making any necessary
`adjustments. Upon a project’s completion, the city would issue a final
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`lot-by-lot assessment. Lot owners could elect to pay the assessment
`in a lump sum or over time in installments.
`After the City completed the Brisbane/Manning Sanitary Sewers
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`Project, it sent affected homeowners formal notice of their payment
`obligations. Of the 180 affected homeowners, 38 elected to pay the
`lump sum. The following year, the City abandoned Barrett Law fi-
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`nancing and adopted the Septic Tank Elimination Program (STEP),
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`which financed projects in part through bonds, thereby lowering indi-
`vidual owner’s sewer-connection costs. In implementing STEP, the
`City’s Board of Public Works enacted a resolution forgiving all as-
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`sessment amounts still owed pursuant to Barrett Law financing.
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`Homeowners who had paid the Brisbane/Manning Project lump sum
`received no refund, while homeowners who had elected to pay in in-
`stallments were under no obligation to make further payments.
`The 38 homeowners who paid the lump sum asked the City for a
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`refund, but the City denied the request. Thirty-one of these home-
`owners brought suit in Indiana state court claiming, in relevant part,
`that the City’s refusal violated the Federal Equal Protection Clause.
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`The trial court granted summary judgment to the homeowners, and
`the State Court of Appeals affirmed. The Indiana Supreme Court re-
`versed, holding that the City’s distinction between those who had al-
`ready paid and those who had not was rationally related to its legiti-
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`ARMOUR v. INDIANAPOLIS
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`Syllabus
`mate interests in reducing administrative costs, providing financial
`hardship relief to homeowners, transitioning from the Barrett Law
`system to STEP, and preserving its limited resources.
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`Held: The City had a rational basis for its distinction and thus did not
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`violate the Equal Protection Clause. Pp. 6–14.
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`(a) The City’s classification does not involve a fundamental right or
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`suspect classification. See Heller v. Doe, 509 U. S. 312, 319–320. Its
`subject matter is local, economic, social, and commercial. See United
`States v. Carolene Products Co., 304 U. S. 144, 152. It is a tax classi-
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`
`fication. See Regan v. Taxation With Representation of Wash., 461
`U. S. 540, 547. And no one claims that the City has discriminated
`against out-of-state commerce or new residents. Cf. Hooper v. Berna-
`lillo County Assessor, 472 U. S. 612. Hence, the City’s distinction
`does not violate the Equal Protection Clause as long as “there is any
`reasonably conceivable state of facts that could provide a rational ba-
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`sis for the classification,” FCC v. Beach Communications, Inc., 508
`U. S. 307, 313, and the “ ‘burden is on the one attacking the [classifi-
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`cation] to negative every conceivable basis which might support it,’ ”
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`Heller, supra, at 320. Pp. 6–7.
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`(b) Administrative concerns can ordinarily justify a tax-related dis-
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`tinction, see, e.g., Carmichael v. Southern Coal & Coke Co., 301 U. S.
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`495, 511–512, and the City’s decision to stop collecting outstanding
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`Barrett Law debts finds rational support in the City’s administrative
`concerns. After the City switched to the STEP system, any decision
`to continue Barrett Law debt collection could have proved complex
`and expensive. It would have meant maintaining an administrative
`system for years to come to collect debts arising out of 20-plus differ-
`ent construction projects built over the course of a decade, involving
`monthly payments as low as $25 per household, with the possible
`need to maintain credibility by tracking down defaulting debtors and
`bringing legal action. The rationality of the City’s distinction draws
`further support from the nature of the line-drawing choices that con-
`fronted it. To have added refunds to forgiveness would have meant
`adding further administrative costs, namely the cost of processing re-
`funds. And limiting refunds only to Brisbane/Manning homeowners
`would have led to complaints of unfairness, while expanding refunds
`to the apparently thousands of other Barrett Law project homeown-
`ers would have involved an even greater administrative burden. Fi-
`nally, the rationality of the distinction draws support from the fact
`that the line that the City drew—distinguishing past payments from
`future obligations—is well known to the law. See, e.g., 26 U. S. C.
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`§108(a)(1)(E). Pp. 7–10.
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`(c) Petitioners’ contrary arguments are unpersuasive. Whether fi-
`nancial hardship is a factor supporting rationality need not be con-
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`2
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` Cite as: 566 U. S. ____ (2012)
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`Syllabus
`sidered here, since the City’s administrative concerns are sufficient to
`show a rational basis for its distinction. Petitioners propose other
`forgiveness systems that they argue are superior to the City’s system,
`but the Constitution only requires that the line actually drawn by the
`City be rational. Petitioners further argue that administrative con-
`siderations alone should not justify a tax distinction lest a city justify
`an unfair system through insubstantial administrative considera-
`tions. Here it was rational for the City to draw a line that avoided
`the administrative burden of both collecting and paying out small
`sums for years to come. Petitioners have not shown that the admin-
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`istrative concerns are too insubstantial to justify the classification.
`Finally, petitioners argue that precedent makes it more difficult for
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`the City to show a rational basis, but the cases to which they refer
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`involve discrimination based on residence or length of residence. The
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`one exception, Allegheny Pittsburgh Coal Co. v. Commission of Web-
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`ster Cty., 488 U. S. 336, is distinguishable. Pp. 10–14.
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`946 N. E. 2d 553, affirmed.
`BREYER, J., delivered the opinion of the Court, in which KENNEDY,
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`THOMAS, GINSBURG, SOTOMAYOR, and KAGAN, JJ., joined. ROBERTS, C. J.,
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` filed a dissenting opinion, in which SCALIA and ALITO, JJ., joined.
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` Cite as: 566 U. S. ____ (2012)
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`Opinion of the Court
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`1
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` NOTICE: This opinion is subject to formal revision before publication in the
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` preliminary print of the United States Reports. Readers are requested to
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` notify the Reporter of Decisions, Supreme Court of the United States, Wash
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` ington, D. C. 20543, of any typographical or other formal errors, in order
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` that corrections may be made before the preliminary print goes to press.
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`SUPREME COURT OF THE UNITED STATES
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`_________________
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` No. 11–161
`_________________
` CHRISTINE ARMOUR, ET AL., PETITIONERS v. CITY
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`OF INDIANAPOLIS, INDIANA, ET AL.
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`ON WRIT OF CERTIORARI TO THE SUPREME COURT OF
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`INDIANA
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`[June 4, 2012]
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` JUSTICE BREYER delivered the opinion of the Court.
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`For many years, an Indiana statute, the “Barrett Law,”
`authorized Indiana’s cities to impose upon benefited lot
`owners the cost of sewer improvement projects. The Law
`also permitted those lot owners to pay either immediately
`in the form of a lump sum or over time in installments.
`In 2005, the city of Indianapolis (City) adopted a new as-
`sessment and payment method, the “STEP” plan, and it
`forgave any Barrett Law installments that lot owners had
`not yet paid.
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`A group of lot owners who had already paid their entire
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`Barrett Law assessment in a lump sum believe that the
`City should have provided them with equivalent refunds.
`And we must decide whether the City’s refusal to do so un-
`constitutionally discriminates against them in violation
`of the Equal Protection Clause, Amdt. 14, §1. We hold
`that the City had a rational basis for distinguishing be
`tween those lot owners who had already paid their share
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`of project costs and those who had not. And we conclude
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`that there is no equal protection violation.
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`2
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` ARMOUR v. INDIANAPOLIS
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`Opinion of the Court
`I
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`A
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`Beginning in 1889 Indiana’s Barrett Law permitted
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`cities to pay for public improvements, such as sewage proj-
`ects, by “apportion[ing]” the costs of a project “equally
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`among all abutting lands or lots.” Ind. Code §36–9–39–
`15(b)(3) (2011); see Town Council of New Harmony v.
`Parker, 726 N. E. 2d 1217, 1227, n. 13 (Ind. 2000) (proj
`ect’s beneficiaries pay its costs). When a city built a Bar
`rett Law project, the city’s public works board would
`create an initial lot-owner assessment by “dividing the
`estimated total cost of the sewage works by the total num
`ber of lots.” §36–9–39–16(a). It might then adjust an
`individual assessment downward if the lot would benefit
`less than would others. §36–9–39–17(b). Upon completion
`of the project, the board would issue a final lot-by-lot
`assessment.
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`The Law permitted lot owners to pay the assessment
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`either in a single lump sum or over time in installment
`payments (with interest). The City would collect install
`ment payments “in the same manner as other taxes.”
`§36–9–37–6. The Law authorized 10-, 20-, or 30-year
`installment plans. §36–9–37–8.5(a). Until fully paid, an
`assessment would constitute a lien against the property,
`permitting the city to initiate foreclosure proceedings in
`case of a default. §§36–9–37–9(b), –22.
`For several decades, Indianapolis used the Barrett Law
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`system to fund sewer projects. See, e.g., Conley v. Brum-
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`mit, 92 Ind. App. 620, 621, 176 N. E. 880, 881 (1931) (in
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`banc). But in 2005, the City adopted a new system, called
`the Septic Tank Elimination Program (STEP), which fi-
`nanced projects in part through bonds, thereby lowering in
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`dividual lot owners’ sewer-connection costs. By that time,
`the City had constructed more than 40 Barrett Law
`projects. App. to Pet. for Cert. 5a. We are told that
`installment-paying lot owners still owed money in respect
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`3
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` Cite as: 566 U. S. ____ (2012)
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`Opinion of the Court
`to 24 of those projects. See Reply Brief for Petitioners 16–
`17, n. 3 (citing City’s Response to Plaintiff ’s Brief on
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`Damages, Record in Cox v. Indianapolis, No. 1:09–cv–0435
`(SD Ind., Doc. 98–1 (Exh. A)). In respect to 21 of the
`24, some installment payments had not yet fallen due; in
`respect to the other 3, those who owed money were in
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`default. Reply Brief for Petitioners 17, n. 3.
`B
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`This case concerns one of the 24 still-open Barrett Law
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`projects, namely the Brisbane/Manning Sanitary Sewers
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`Project. The Brisbane/Manning Project began in 2001. It
`connected about 180 homes to the City’s sewage system.
`Construction was completed in 2003. The Indianapolis
`Board of Public Works held an assessment hearing in
`June 2004. And in July 2004 the Board sent the 180
`affected homeowners a formal notice of their payment
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`obligations.
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`The notice made clear that each homeowner could pay
`the entire assessment—$9,278 per property—in a lump
`sum or in installments, which would include interest at a
`3.5% annual rate. Under an installment plan, payments
`would amount to $77.27 per month for 10 years; $38.66
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`per month for 20 years; or $25.77 per month for 30 years.
`In the event, 38 homeowners chose to pay up front; 47
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`chose the 10-year plan; 27 chose the 20-year plan; and 68
`chose the 30-year plan. And in the first year each home
`owner paid the amount due ($9,278 upfront; $927.80
`under the 10-year plan; $463.90 under the 20-year plan, or
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`$309.27 under the 30-year plan). App. to Pet. for Cert.
`48a.
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`The next year, however, the City decided to abandon the
`Barrett Law method of financing. It thought that the
`Barrett Law’s lot-by-lot payments had become too burden
`some for many homeowners to pay, discouraging changes
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`from less healthy septic tanks to healthier sewer systems.
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` ARMOUR v. INDIANAPOLIS
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`Opinion of the Court
`(For example, homes helped by the
`See id., at 4a–5a.
`Brisbane/Manning Project, at a cost of more than $9,000
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`each, were then valued at $120,000 to $270,000. App. 67.)
`The City’s new STEP method of financing would charge
`each connecting lot owner a flat $2,500 fee and make up
`the difference by floating bonds eventually paid for by all
`lot owners citywide. See App. to Pet. for Cert. 5a, n. 5.
`
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`On October 31, 2005, the City enacted an ordinance
`implementing its decision. In December, the City’s Board
`of Public Works enacted a further resolution, Resolution
`101, which, as part of the transition, would “forgive all
`assessment amounts . . . established pursuant to the Bar
`rett Law Funding for Municipal Sewer programs due and
`owing from the date of November 1, 2005 forward.” App.
`72 (emphasis added). In its preamble, the Resolution said
`that the Barrett Law “may present financial hardships on
`many middle to lower income participants who most need
`sanitary sewer service in lieu of failing septic systems”;
`it pointed out that the City was transitioning to the new
`STEP method of financing; and it said that the STEP
`method was based upon a financial model that had “con
`sidered the current assessments being made by partici
`pants in active Barrett Law projects” as well as future
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`projects. Id., at 71–72. The upshot was that those who
`still owed Barrett Law assessments would not have to
`make further payments but those who had already paid
`their assessments would not receive refunds. This meant
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`that homeowners who had paid the full $9,278 Brisbane/
`Manning Project assessment in a lump sum the preced-
`ing year would receive no refund, while homeowners
`who had elected to pay the assessment in installments, and
`had paid a total of $309.27, $463.90, or $927.80, would
`be under no obligation to make further payments.
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`In February 2006, the 38 homeowners who had paid the
`full Brisbane/Manning Project assessment asked the City
`for a partial refund (in an amount equal to the smallest
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` Cite as: 566 U. S. ____ (2012)
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`Opinion of the Court
`forgiven Brisbane/Manning installment debt, apparently
`$8,062). The City denied the request in part because
`“[r]efunding payments made in your project area, or any
`portion of the payments, would establish a precedent of
`unfair and inequitable treatment to all other property
`owners who have also paid Barrett Law assessments . . .
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`and while [the November 1, 2005, cutoff date] might seem
`arbitrary to you, it is essential for the City to establish
`this date and move forward with the new funding ap
`proach.” Id., at 50–51.
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`C
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`Thirty-one of the thirty-eight Brisbane/Manning Project
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`lump-sum homeowners brought this lawsuit in Indiana
`state court seeking a refund of about $8,000 each. They
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`claimed in relevant part that the City’s refusal to provide
`them with refunds at the same time that the City forgave
`the outstanding Project debts of other Brisbane/Manning
`homeowners violated the Federal Constitution’s Equal Pro-
`tection Clause, Amdt. 14, §1; see also Rev. Stat. §1979,
`42 U. S. C. §1983. The trial court granted summary
`judgment in their favor. The State Court of Appeals af
`firmed that judgment. 918 N. E. 2d 401 (2009). But the
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`Indiana Supreme Court reversed. 946 N. E. 2d 553 (2011).
`In its view, the City’s distinction between those who had
`already paid their Barrett Law assessments and those
`who had not was “rationally related to its legitimate inter
`ests in reducing its administrative costs, providing relief
`for property owners experiencing financial hardship,
`establishing a clear transition from [the] Barrett Law to
`STEP, and preserving its limited resources.” App. to Pet.
`for Cert. 19a. We granted certiorari to consider the equal
`protection question. And we now affirm the Indiana Su
`preme Court.
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` ARMOUR v. INDIANAPOLIS
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`Opinion of the Court
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` II
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`A
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`As long as the City’s distinction has a rational basis,
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`that distinction does not violate the Equal Protection
`Clause. This Court has long held that “a classification
`neither involving fundamental rights nor proceeding along
`suspect lines . . . cannot run afoul of the Equal Protection
`Clause if there is a rational relationship between the dis-
`parity of treatment and some legitimate governmental
`purpose.” Heller v. Doe, 509 U. S. 312, 319–320 (1993); cf.
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`Gulf, C. & S. F. R. Co. v. Ellis, 165 U. S. 150, 155, 165–166
`
`(1897). We have made clear in analogous contexts that,
`where “ordinary commercial transactions” are at issue, ra-
`tional basis review requires deference to reasonable under
`lying legislative judgments. United States v. Carolene
`Products Co., 304 U. S. 144, 152 (1938) (due process);
`see also New Orleans v. Dukes, 427 U. S. 297, 303 (1976)
`(per curiam) (equal protection). And we have repeatedly
`pointed out that “[l]egislatures have especially broad
`latitude in creating classifications and distinctions in tax
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`statutes.” Regan v. Taxation With Representation of
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`Wash., 461 U. S. 540, 547 (1983); see also Fitzgerald v.
`Racing Assn. of Central Iowa, 539 U. S. 103, 107–108
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`(2003); Nordlinger v. Hahn, 505 U. S. 1, 11 (1992);
`Lehnhausen v. Lake Shore Auto Parts Co., 410 U. S. 356,
`359 (1973); Madden v. Kentucky, 309 U. S. 83, 87–88
`(1940); Citizens’ Telephone Co. of Grand Rapids v. Fuller,
`229 U. S. 322, 329 (1913).
`
`Indianapolis’ classification involves neither a “funda
`mental right” nor a “suspect” classification. Its subject
`matter is local, economic, social, and commercial. It is a
`tax classification. And no one here claims that Indianapo
`lis has discriminated against out-of-state commerce or new
`residents. Cf. Hooper v. Bernalillo County Assessor, 472
`U. S. 612 (1985); Williams v. Vermont, 472 U. S. 14 (1985);
`Metropolitan Life Ins. Co. v. Ward, 470 U. S. 869 (1985);
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` Cite as: 566 U. S. ____ (2012)
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`Opinion of the Court
` Zobel v. Williams, 457 U. S. 55 (1982). Hence, this case
`
`
`falls directly within the scope of our precedents holding
`such a law constitutionally valid if “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.” Nordlinger, supra, at 11 (citations
`omitted). And it falls within the scope of our precedents
`holding that there is such a plausible reason if “there is
`any reasonably conceivable state of facts that could pro
`vide a rational basis for the classification.” FCC v. Beach
`Communications, Inc., 508 U. S. 307, 313 (1993); see also
`Lindsley v. Natural Carbonic Gas Co., 220 U. S. 61, 78
`
`
`(1911).
`Moreover, analogous precedent warns us that we are not
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`to “pronounc[e]” this classification “unconstitutional un
`less in the light of the facts made known or generally
`assumed it is of such a character as to preclude the as
`sumption that it rests upon some rational basis within
`the knowledge and experience of the legislators.” Carolene
`Products Co., supra, at 152 (due process claim). Further,
`because the classification is presumed constitutional, the
`“‘burden is on the one attacking the legislative arrange
`ment to negative every conceivable basis which might
`support it.’” Heller, supra, at 320 (quoting Lehnhausen,
`supra, at 364).
`
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`B
`
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`In our view, Indianapolis’ classification has a rational
`basis. Ordinarily, administrative considerations can jus-
`
`
`tify a tax-related distinction. See, e.g., Carmichael v.
`Southern Coal & Coke Co., 301 U. S. 495, 511–512 (1937)
`(tax exemption for businesses with fewer than eight em
`ployees rational in light of the “[a]dministrative conven
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`8
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` ARMOUR v. INDIANAPOLIS
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`Opinion of the Court
`ience and expense” involved); see also Lehnhausen, supra,
`at 365 (comparing administrative cost of taxing corpora
`tions versus individuals); Madden, supra, at 90 (compar
`ing administrative cost of taxing deposits in local banks
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`versus those elsewhere). And the City’s decision to stop
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`collecting outstanding Barrett Law debts finds rational
`support in related administrative concerns.
`The City had decided to switch to the STEP system.
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`After that change, to continue Barrett Law unpaid-debt
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`collection could have proved complex and expensive. It
`would have meant maintaining an administrative system
`that for years to come would have had to collect debts
`arising out of 20-plus different construction projects built
`over the course of a decade, involving monthly payments
`as low as $25 per household, with the possible need
`to maintain credibility by tracking down defaulting debt
`ors and bringing legal action. The City, for example,
`would have had to maintain its Barrett Law operation
`within the City Controller’s Office, keep files on old, small,
`installment-plan debts, and (a City official says) possibly
`spend hundreds of thousands of dollars keeping computer
`ized debt-tracking systems current. See Brief for Interna
`tional City/County Management Association et al. as
`Amici Curiae 13, n. 12 (citing Affidavit of Charles White
`¶13, Record in Cox, Doc. No. 57–3). Unlike the collection
`system prior to abandonment, the City would not have
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`added any new Barrett Law installment-plan debtors.
`And that fact means that it would have had to spread the
`fixed administrative costs of collection over an ever
`declining number of debtors, thereby continuously increas
`ing the per-debtor cost of collection.
`
`Consistent with these facts, the Director of the City’s
`Department of Public Works later explained that the City
`decided to forgive outstanding debt in part because “[t]he
`administrative costs to service and process remaining
`balances on Barrett Law accounts long past the transition
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` Cite as: 566 U. S. ____ (2012)
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`Opinion of the Court
`to the STEP program would not benefit the taxpayers” and
`would defeat the purpose of the transition. App. 76. The
`four other members of the City’s Board of Public Works
`have said the same. See Affidavit of Gregory Taylor ¶6,
`Record in Cox, Doc. No. 57–5; Affidavit of Kipper Tew ¶6,
`ibid. Doc. No. 57–6; Affidavit of Susan Schalk ¶6, ibid.
`Doc. No. 57–7; Affidavit of Roger Brown ¶6, ibid. Doc.
`No. 57–8.
`
`The rationality of the City’s distinction draws further
`
`
`support from the nature of the line-drawing choices that
`confronted it. To have added refunds to forgiveness would
`have meant adding yet further administrative costs,
`namely the cost of processing refunds. At the same time,
`to have tried to limit the City’s costs and lost revenues by
`limiting forgiveness (or refund) rules to Brisbane/Manning
`homeowners alone would have led those involved in other
`Barrett Law projects to have justifiably complained about
`unfairness. Yet to have granted refunds (as well as pro-
`viding forgiveness) to all those involved in all Barrett
`Law projects (there were more than 40 projects) or in
`all open projects (there were more than 20) would have
`involved even greater administrative burden. The City
`could not just “cut . . . checks,” post, at 4 (ROBERTS, C. J.,
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`dissenting), without taking funding from other programs
`or finding additional revenue. If, instead, the City had
`tried to keep the amount of revenue it lost constant (a
`rational goal) but spread it evenly among the apparently
`thousands of homeowners involved in any of the Barrett
`Laws projects, the result would have been yet smaller
`individual payments, even more likely to have been too
`small to justify the administrative expense.
`
`Finally, the rationality of the distinction draws support
`from the fact that the line that the City drew—
`distinguishing past payments from future obligations—is
`a line well known to the law. Sometimes such a line takes
`the form of an amnesty program, involving, say, mortgage
`
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`9
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` ARMOUR v. INDIANAPOLIS
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`Opinion of the Court
`payments, taxes, or parking tickets. E.g., 26 U. S. C.
`§108(a)(1)(E) (2006 ed., Supp. IV) (federal income tax
`provision allowing homeowners to omit from gross income
`newly forgiven home mortgage debt); United States v.
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`Martin, 523 F. 3d 281, 284 (CA4 2008) (tax amnesty pro
`gram whereby State newly forgave penalties and liabili
`ties if taxpayer satisfied debt); Horn v. Chicago, 860 F. 2d
`700, 704, n. 9 (CA7 1988) (city parking ticket amnesty
`program whereby outstanding tickets could be newly set
`tled for a fraction of amount specified). This kind of
`line is consistent with the distinction that the law often
`makes between actions previously taken and those yet to
`come.
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`C
`Petitioners’ contrary arguments are not sufficient to
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`change our conclusion. Petitioners point out that the
`Indiana Supreme Court also listed a different considera
`tion, namely “financial hardship,” as one of the factors
`supporting rationality. App. to Pet. for Cert. 19a. They
`refer to the City’s resolution that said that the Barrett
`Law “may present financial hardships on many middle to
`lower income participants who most need sanitary sewer
`service in lieu of failing septic systems.” App. 71. And
`they argue that the tax distinction before us would not
`necessarily favor low-income homeowners.
`We need not consider this argument, however, for the
`
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`administrative considerations we have mentioned are
`sufficient to show a rational basis for the City’s distinc
`tion. The Indiana Supreme Court wrote that the City’s
`classification was “rationally related” in part “to its legit
`imate interests in reducing its administrative costs.” App.
`to Pet. for Cert. 19a (emphasis added). The record of the
`City’s proceedings is consistent with that determination.
`See App. 72 (when developing transition, the City “consid
`ered the current assessments being made by participants
`in active Barrett Law projects”). In any event, a legisla
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`Opinion of the Court
`ture need not “actually articulate at any time the purpose
`
`or rationale supporting its classification.” Nordlinger, 505
`
`U. S., at 15; see also Fitzgerald, 539 U. S., at 108 (similar).
`Rather, the “burden is on the one attacking the legislative
`arrangement to negative every conceivable basis which
`might support it.” Madden, 309 U. S., at 88; see Heller,
`509 U. S., at 320 (same); Lehnhausen, 410 U. S., at 364
`(same); see also Allied Stores of Ohio, Inc. v. Bowers, 358
`U. S. 522, 530 (1959) (upholding state tax classification
`resting “upon a state of facts that reasonably can be con
`ceived” as creating a rational distinction). Petitioners
`have not “negative[d]” the Indiana Supreme Court’s first
`listed justification, namely the administrative concerns we
`have discussed.
`
`Petitioners go on to propose various other forgiveness
`systems that would have included refunds for at least
`some of those who had already paid in full. They argue
`that those systems are superior to the system that the
`City chose. We have discussed those, and other possible,
`systems earlier. Supra, at 8–9. Each has advantages and
`disadvantages. But even if petitioners have found a supe
`rior system, the Constitution does not require the City to
`draw the perfect line nor even to draw a line superior to
`some other line it might have drawn. It requires only that
`the line actually drawn be a rational line. And for the
`reasons we have set forth in Part II–B, supra, we believe
`that the line the City drew here is rational.
`
`Petitioners further argue that administrative considera
`tions alone should not justify a tax distinction, lest a city
`arbitrarily allocate taxes among a few citizens while for
`giving many similarly situated citizens on the ground that
`it is cheaper and easier to collect taxes from a few people
`than from many. Brief for Petitioners 45. Petitioners are
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`right that administrative considerations could not justify
`such an unfair system. But that is not because adminis
`trative considerations can never justify tax differences
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` ARMOUR v. INDIANAPOLIS
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`Opinion of the Court
`(any more than they can always do so). The question is
`whether reducing those expenses, in the particular cir
`cumstances, provides a rational basis justifying the tax
`difference in question.
`
`In this case, “in the light of the facts made known or
`
`generally assumed,” Carolene Products Co., 304 U. S., at
`152, it is reasonable to believe that to graft a refund sys
`tem onto the City’s forgiveness decision could have (for
`example) imposed an administrative burden of both col
`lecting and paying out small sums (say, $25 per month) for
`
`years. As we have said, supra, at 7–9, it is rational for the
`City to draw a line that avoids that burden. Petitioners,
`who are the ones “attacking the legislative arrangement,”
`have the burden of showing that the circumstances are
`otherwise, i.e., that the administrative burden is too in
`substantial to justify the classification. That they have
`not done.
`
`Finally, petitioners point to precedent that in their view
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`makes it more difficult than we have said for the City to
`show a “rational basis.” With but one exception, however,
`the cases to which they refer involve discrimination based
`on residence or length of residence. E.g., Hooper v. Berna-
`lillo County Assessor, 472 U. S. 612 (state tax preference
`distinguishing between long-term and short-term resident
`veterans); Williams v. Vermont, 472 U. S. 14 (state use tax
`
`
`that burdened out-of-state car buyers who moved in-state);
`Metropolitan Life Ins. Co. v. Ward, 470 U. S. 869 (state
`law that taxed out-of-state insurance companies at a
`higher rate than in-state companies); Zobel v. Williams,
`457 U. S. 55 (state dividend distribution system that
`favored long-term residents). But those circumstances are
`not present here.
`The exception consists of Allegheny Pittsburgh Coal Co.
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`v. Commission of Webster Cty., 488 U. S. 336 (1989). The
`Court there took into account a state constitution and
`related laws that required equal valuation of equally
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`Opinion of the Court
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` valuable property. Id., at 345. It considered the constitu
`tionality of a county tax assessor’s practice (over a period
`of many years) of determining property values as of the
`time of the property’s last sale; that practice meant highly
`unequal valuations for two identical properties that were
`sold years or decades apart. Id., at 341. The Court first
`found that the assessor’s practice was not rationally re
`lated to the county’s avowed purpose of assessing proper
`ties equally at true current value because of the intentional
`systemic discrepancies the practice created. Id., at 343–
`344. The Court then noted that, in light of the state con
`stitution and related laws requiring equal valuation, there
`could be no other rational basis for the practice. Id., at
`344–345. Therefore, the Court held, the assessor’s dis
`criminatory policy violated the Federal Constitution’s
`insistence upon “equal protection of the law.” Id., at 346.
`
`Petitioners argue that the City’s refusal to add refunds
`
`to its forgiveness decision is similar, for it constitutes a
`refusal to apply “equally” an Indiana state law that says
`that the costs of a Barrett Law project shall be equally
`“apportioned.”
`Ind. Code §36–9–39–15(b)(3). In other
`words, petitioners say that even if the City’s decision
`might otherwise be related to a rational purpose, state law