## Facts

- Indianapolis funded certain sewer projects under Indiana’s “Barrett Law,” allowing special assessments apportioned equally among abutting lots.
- Property owners could pay an assessment either in a single lump sum or through multi-year installments, with interest and liens securing unpaid balances.
- For the Brisbane/Manning (Northern Estates) sewer project, the City assessed roughly $9,278 per property; 38 of 180 owners paid in a lump sum, while others chose installments.
- In 2005, the City replaced Barrett Law financing with the Septic Tank Elimination Program (STEP), funded in part by bonds and intended to reduce costs and address hardship concerns.
- During the transition, the City forgave all outstanding Barrett Law installment balances as of November 1, 2005, but did not refund any portion of assessments already paid in full.
- As a result, some lump-sum payers paid the full assessment while similarly situated installment payers paid only a fraction before forgiveness.

## Issues

1. Whether the Equal Protection Clause forbids a city from forgiving unpaid special-assessment installments while denying refunds to homeowners who previously paid the same assessment in full.

## Decision

- The Supreme Court affirmed the Indiana Supreme Court.
- The Court held that the City’s decision not to refund lump-sum payers while forgiving unpaid installment balances did not violate the Equal Protection Clause.
- Applying rational-basis review, the Court concluded the classification between owners who had already paid and those who had not was rationally related to legitimate governmental interests.

## Legal Principles

- Economic and taxation-related classifications that do not burden a fundamental right or target a suspect class are reviewed under highly deferential rational-basis scrutiny.
- A classification survives equal protection review if there is any conceivable rational basis supporting it; perfect equality and “mathematical nicety” are not required.
- Administrative cost savings and simplification can provide a rational basis for differential treatment in tax or assessment administration.
- A government may rationally implement a transition between financing systems by forgiving future obligations without reopening completed transactions through refunds.
- Disparities among similarly situated taxpayers do not alone establish an equal protection violation absent irrational line-drawing; transitional policies may be distinguished from intentional, systematic inequality.

## Conclusion

Indianapolis’s choice to forgive unpaid sewer-assessment installments during a financing transition, while denying refunds to homeowners who had already paid in full, was constitutionally permissible because it was rationally related to legitimate administrative and fiscal objectives.


Armour v. City of Indianapolis, 566 U.S. 673 (2012)