City of Indianapolis v. Armour, 946 N.E.2d 553

The City of Indianapolis switched from Barrett Law financing to STEP for sanitary sewers, aiming to reduce burdens on middle-/low-income property owners.
As part of the transition, the City discharged all Barrett Law balances outstanding as of November 1, 2005, through Resolution 101, but did not issue refunds to those who had already paid their assessments.
40+ Barrett Law projects were affected; some taxpayers paid upfront, others paid over time, with installments accruing interest.
Plaintiffs owned 31 parcels in the Brisbane/Manning project and had paid their Barrett Law assessments in full; they sought refunds for balances forgiven by Resolution 101.
The trial court ruled for plaintiffs on the equal protection claim; the Court of Appeals reversed, holding there was no rational basis for the City’s differential treatment; the Indiana Supreme Court granted transfer.
The Supreme Court held that Resolution 101 satisfies rational basis review and did not violate the Equal Protection Clause, reversing the trial court and remanding for judgment for the City.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did Resolution 101 violate equal protection by forgiving outstanding Barrett Law balances while not refunding amounts paid in full?	Armour asserts no rational basis for differential relief.	City argues relief toward broad financial-harm reduction is rational and non-discriminatory.	No; Resolution 101 rationally related to legitimate interests and withstands rational-basis review.
Should the Court apply a class-of-one analysis to determine rationality of the City's action?	Court of Appeals erred by treating as class-of-one; the decision targeted outstanding balances across projects.	Resolution 101 classified by outstanding Barrett Law balances, a plausible policy group.	Not a class-of-one case; classification is by broad project-wide outstanding balances and survives rational basis review.

Nordlinger v. Hahn, 505 U.S. 1 (U.S. 1992) (upholds rational-basis review for tax classifications when plausible and related to legitimate interests)
Beach Communications, Inc. v. FCC, 508 U.S. 307 (U.S. 1993) (rational basis review requires plausible policy reasons; not every hardship invalidates law)
Clove Leaf Creamery Co. v. Minnesota, 449 U.S. 456 (U.S. 1981) (illustrates how legislatures may rely on plausible policies even if outcomes seem unequal)
Allegheny Pittsburgh Coal Co. v. Webster County Comm'n, 488 U.S. 336 (U.S. 1989) (class-of-one label used; distinguished as aberrational and not controlling here)
Olech v. Willowbrook, 528 U.S. 562 (U.S. 2000) (recognizes cognizable equal protection claim for arbitrary treatment of individuals not in a class)
Engquist v. Oregon Dept. of Agric., 553 U.S. 591 (U.S. 2008) (discusses limits of class-based equal protection claims when no suspect class exists)
Fitzgerald v. Racing Sen. Ass'n of Cent. Iowa, 539 U.S. 103 (U.S. 2003) (upholds governmental interest in adjusting benefits under budgetary constraints)
City of Cleburne v. Cleburne Living Center, 473 U.S. 432 (U.S. 1985) (limits strict scrutiny to classifications with irrational or arbitrary basis)