Armour v. Indianapolis

The Equal Protection Clause does not prohibit a city from distinguishing between landowners who have paid their assessments and landowners who have not when changing assessment systems for improvement projects.

In 2005, Indianapolis abandoned its practice of apportioning the cost of sewer projects to the owners of improved property and switched to a bond system. Prior to the switch, landowners were given the option of paying a lump sum or paying the assessment in installments. When the switch was made, landowners paying in installments were forgiven their debt. Petitioners, who had paid the lump sum, sought a partial refund. The trial court granted summary judgment for Petitioners, the appellate court affirmed, and the Indiana Supreme Court reversed.

The Court affirmed the Indiana Supreme Court and reasoned that legislatures have broad authority to create classifications in tax systems and since the city's distinction was based on the administrative costs of refunding the petitioners that Indianapolis had a rational basis for distinguishing between lot owners who had already paid their assessments and owners who had not. Additionally, the line that the city chose to draw, distinguishing past payments from future obligation, is well known to the law, and the equal protection clause only requires a rational line, not a perfect line, thus, distinguishing between the two groups is not an equal protection violation.