Allegheny Pittsburgh Coal Co. v. County Commission of Webster County, West Virginia

Summary

Chief Justice Rehnquist, writing for a unanimous Court, held that Webster County violated equal protection by assessing petitioners’ recently purchased property at values roughly 8 to 35 times those assigned to comparable neighboring property, with disparities persisting for more than a decade. Although purchase-price assessments and transitional adjustments are not inherently unconstitutional, the county’s adjustments failed to achieve rough equality within a reasonable time. The State could not restrict petitioners to seeking increases in other taxpayers’ assessments. The Court reversed and remanded, expressly leaving unresolved whether a similar acquisition-value system adopted and generally applied statewide would be constitutional. There were no separate opinions.