## Facts

- Webster County, West Virginia imposed ad valorem taxes on coal-bearing land owned by Allegheny Pittsburgh Coal Co. and related entities.
- The West Virginia Constitution required property to be taxed in proportion to value and contemplated uniform treatment among comparable property.
- From 1975 to 1986, the county assessor valued recently purchased property based largely on its arm’s-length purchase price.
- For property not recently transferred, the assessor generally carried forward prior assessments with only minor modifications rather than reappraising to current value.
- The method produced large and persistent differences in assessed values among generally comparable neighboring properties.
- Petitioners’ properties were assessed at roughly 8 to 35 times the assessed value of comparable properties, and the disparities persisted for more than a decade with little change.
- The county commission annually affirmed the assessments despite petitioners’ challenges.
- A state circuit court found systematic and intentional discrimination and ordered reductions consistent with state tax commissioner guidelines, but the state supreme court reversed, reasoning there was no equal protection problem if petitioners were not assessed above “true value.”

## Issues

1. Whether a county violates the Fourteenth Amendment’s Equal Protection Clause by assessing recently sold property near full purchase price while leaving older assessments of comparable property largely unchanged for many years, resulting in substantial and enduring disparities.

## Decision

- The U.S. Supreme Court reversed the state supreme court and held unanimously that the assessments violated the Equal Protection Clause.
- The Court accepted that purchase-price-based assessment is not unconstitutional by itself, but held that the county’s administration failed to produce even rough equality among similarly situated taxpayers within a reasonable time.
- The case was remanded for further proceedings consistent with the Court’s ruling.

## Legal Principles

- Equal Protection in taxation does not require precise mathematical uniformity, but it forbids a scheme that imposes substantially unequal tax burdens on similarly situated property owners.
- An assessment approach using recent purchase price plus general adjustments for other parcels may be permissible as a temporary measure, but only if adjustments are sufficient to achieve rough equality over a short period.
- A taxpayer can establish an equal protection violation where the taxing authority’s consistent practice produces gross assessment disparities of significant duration, even if the taxpayer’s own assessment does not exceed market value.
- Equal protection analysis focuses on comparative treatment within the relevant class; a state cannot shift the burden of correcting widespread undervaluation onto the disadvantaged taxpayer by requiring the taxpayer to seek increases in others’ assessments.

## Conclusion

Webster County’s practice of assessing newly purchased parcels near purchase price while effectively freezing many older assessments created extreme, long-term disparities among comparable properties, denying petitioners the rough equality required by the Equal Protection Clause.


Allegheny Pittsburgh Coal Co. v. County Comm’n of Webster Cnty., 488 U.S. 336 (1989)