Hoffmann v. Clark

An Illinois statute allowed real estate that had been used for farming or agricultural purposes for three consecutive years to be valued for property-tax purposes on the basis of its agricultural use rather than its fair market value, which was how real estate was normally valued. This allowed for lower property taxes for agricultural property. The statute provided that if the property was no longer used for farming or agricultural purposes, the landowner would be required to pay the difference between the taxes actually paid over the previous three years and the taxes that would have been paid had the property been valued at its fair market value, along with 5 percent interest on that difference. Hoffman and other landowners (plaintiffs) filed a lawsuit seeking declaratory judgment and injunctive relief against county and state officials (defendants), alleging that the statute was an unconstitutional violation of equal protection and due process and that the statute violated the Illinois Constitution because it constituted an impermissible legislative classification of real estate for taxation purposes. The trial court ruled that the legislature could constitutionally grant a favorable tax status to agricultural property but that the provision that allowed three years’ worth of taxes to be recouped was unconstitutional. County and state officials appealed.