Armour v. City of Indianapolis
132 S. Ct. 2073
| SCOTUS | 2012Background
- Indiana’s Barrett Law allowed cities to apportion sewer costs among abutting lands, with lump-sum or installment payments and liens for nonpayment.
- In 2005 Indianapolis adopted STEP, financing projects via bonds and forgiving outstanding Barrett Law installments, but did not refund lump-sum payers.
- Brisbane/Manning Sanitary Sewers Project (2001–2003) connected ~180 homes; per-property cost was $9,278, with varied payment choices (lump sum, 10-, 20-, or 30-year installments).
- After switching to STEP, the city enacted resolutions forgiving Barrett Law debt from November 1, 2005 onward but denying refunds to lump-sum payers who had fully paid earlier.
- The 38 lump-sum payers sought about $8,000 each in refunds; the city denied refunds citing administrative and fairness considerations, prompting a state court suit invoking the Equal Protection Clause.
- The Indiana Supreme Court affirmed the city’s decision; the U.S. Supreme Court granted certiorari and upheld the rational-basis justification for the distinction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the City’s forgiveness without refunds for lump-sum payers violates equal protection | Brisbane/Manning lump-sum payers | City had a rational basis to avoid administrative costs | No violation; rational basis supports the distinction |
| Whether the City’s line drawing was rational under welfare of government interests | Administrative burden argues against the policy | Classification supported by administrative and transition considerations | Rational basis upheld; line drawing reasonable |
| Whether Allegheny Pittsburgh Coal governs here | Allegheny requires equal treatment under state law | Allegheny distinguished by clear state-law violation | Allegheny not controlling; state law permitted forgiveness without requiring refunds |
Key Cases Cited
- Nordlinger v. Hahn, 505 U.S. 1 (1992) (defer to legislative judgments with rational basis)
- Heller v. Doe, 509 U.S. 312 (1993) (rational basis review for classifications not based on fundamental rights or suspect classes)
- FCC v. Beach Communications, Inc., 508 U.S. 307 (1993) (plausible facts can support rational basis for classification)
- Lehnhausen v. Lake Shore Auto Parts Co., 410 U.S. 356 (1973) (administrative convenience as basis for tax distinctions)
- Madden v. Kentucky, 309 U.S. 83 (1940) (legislative latitude in classifying for taxation)
- Carmichael v. Southern Coal & Coke Co., 301 U.S. 495 (1937) (administrative considerations in tax schemes permissible)
- Allegheny Pittsburgh Coal Co. v. Commission of Webster Cty., 488 U.S. 336 (1989) (equal protection violation where tax system unreasonably discriminates among similarly situated property owners)