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Nordlinger v. Hahn

505 U.S. 1, 112 S. Ct. 2326 (1992)

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Nordlinger v. Hahn

United States Supreme Court

505 U.S. 1, 112 S. Ct. 2326 (1992)

Facts

In the 1960 and 1970s, property values and, subsequently, property taxes in California rose rapidly. In 1978 a ballot initiative called Proposition 13 was adopted. Proposition 13 capped property taxes at 1 percent of a property’s full cash value, meaning its value assessed in 1975. If a change in ownership occurred after 1975, the property value would be reassessed to the appraised value of the property when newly constructed or purchased. Proposition 13 also included two exemptions to the reassessment provision: one allowing homeowners over the age of 55 to carry over their property assessments if they purchased a replacement property of equal or lesser value, and one allowing parents to transfer a principal residence to their children without triggering a reassessment. Proposition 13 led to disparities between property taxes owed by long-term property owners and new property owners with similar properties. Stephanie Nordlinger (plaintiff) purchased a home in Los Angeles in 1988 for $170,000. The Los Angeles County tax assessor (the assessor) (defendant) notified Nordlinger that her tax liability would be $1,701 for the 1988 fiscal year, a 36 percent increase over what the previous owners paid and five times more than what her neighbors who owned similar homes paid. Nordlinger filed a lawsuit against the assessor and other officials in Los Angeles County Superior Court, arguing that the property-tax scheme imposed by Proposition 13 was unconstitutional under the Fourteenth Amendment’s Equal Protection Clause because it resulted in disparate tax liabilities for owners of similar properties. The superior court dismissed the complaint. The court of appeal affirmed, and the California Supreme Court denied review.

Rule of Law

Issue

Holding and Reasoning (Blackmun, J.)

Dissent (Stevens, J.)

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