Town of Secaucus v. Hudson County Board of Taxation
New Jersey Supreme Court
628 A.2d 288 (1993)

- Written by Sean Carroll, JD
Facts
The City of Bayonne, which was part of Hudson County (the county) (defendant), had operated a successful vocational-education program since 1931. In the 1970s, the county began operating the Hudson County Vocational School (HCVS). The county and the state legislature acknowledged Bayonne’s preexisting program and wished to avoid forcing Bayonne to pay for HCVS, a school from which it would not benefit. A bill was filed to exempt municipalities from taxes paying for vocational schools in their counties if the municipalities had their own vocational school already. The bill as written, however, would apply more broadly than only to Bayonne. As a result, an amendment was filed to restrict the tax exemption to municipalities in “first class” counties that had populations of less than 700,000. First-class counties in New Jersey were defined as those with populations of at least 600,000. In addition, the amendment limited the exemption to municipalities with vocational programs over 20 years old. Under the amendment, Bayonne was the only municipality in the state to which the exemption applied. Ultimately, the bill was enacted as amended. To implement the new tax statute, the county assessed a lower rate of taxes to Bayonne than it did in its other 11 municipalities. The Town of Secaucus (plaintiff), one of those other municipalities, sued the county, claiming that the statute violated New Jersey’s prohibition on special legislation.
Rule of Law
Issue
Holding and Reasoning (Handler, J.)
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