Port Jefferson Health Care Facility, Respondents v. Brian Wing, as Acting Commissioner of Social Services of…

Summary

The New York Court of Appeals reversed the Appellate Division and held that the statutory scheme imposing a 1.2% and 3.8% gross receipts tax on residential health care facilities, while reimbursing the tax on Medicaid receipts, is constitutional under the rational basis standard of equal protection review. The Court affirmed that the classification creates a discrete class but is justified by legitimate state interests in encouraging care for indigent patients and reducing incentives to favor private‑pay patients.