Allegheny Pittsburgh Coal Co. v. County Commission of Webster County, West Virginia (488 U.S. 336)
U.S. Supreme Court · decided January 18, 1989 · Supreme Court Database (Spaeth)
- Citation
- 488 U.S. 336 · 109 S. Ct. 633
- Decided
- January 18, 1989
- Term
- October Term 1988
- Vote
- 9–0
- Majority author
- Justice Rehnquist
- Issue area
- Economic Activity
- Disposition
- Reversed and remanded
- Outcome
- Petitioning party won
- Ideological direction
- Conservative
- Constitutional ruling
- State/territorial law held unconstitutional
Opinion excerpt
Chief Justice. Rehnquist delivered the opinion of the Court. The West Virginia Constitution guarantees to its citizens that, with certain exceptions, “taxation shall be equal and uniform throughout the State, and all property, both real and personal, shall be taxed in proportion to its value . . . .” Art. X, § 1. The Webster County tax assessor valued petitioners’ real property on the basis of its recent purchase price, but made only minor modifications in the assessments of land which had not been recently sold. This practice resulted in gross disparities in the assessed value of generally comparable property, and we hold that it denied petitioners the equal protection of the laws guaranteed to them by the Fourteenth Amendment. Between 1975 and 1986, the tax assessor for Webster County, West Virginia, fixed yearly assessments for property within the county at 50% of appraised value. She fixed the appraised value at the declared consideration at which the property last sold. Some adjustments were made in the assessments of properties that had not been recently sold, although they amounted to, at most, 10% increases in 1976, 1981, and 1983 respectively. In 1974, for example, Allegheny Pittsburgh Coal Company (Allegheny) purchased fee, surface, and mineral interests in certain properties for a stated price somewhat in excess of $24 million, and during the tax years 1976 through…
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