Foss v. City of Rochester, 66 N.Y.2d 872 (1985)

A state law that results in demonstrably different county tax burdens based solely on geographic location violates the equal protection clauses of the Federal and State Constitutions.

Summary

This case addresses whether Real Property Tax Law article 19-A, enacted after the Court of Appeals found a similar prior law unconstitutional in Foss v. City of Rochester, violates the equal protection clauses. The prior law established arbitrary tax distinctions between non-homestead property in Rochester and similarly situated properties elsewhere in Monroe County. The Court held that article 19-A, which shifted tax calculation responsibility but did not address interjurisdictional equality, perpetuated the unconstitutional geographic tax disparities. The court reaffirmed its prior holding, finding that the constitutional deficiency remained uncured because taxpayers in different assessing units were still subject to unequal county tax burdens. Therefore, article 19-A was declared unconstitutional.

Facts

Following the Court of Appeals’ decision in Foss v. City of Rochester (65 NY2d 247), which struck down Real Property Tax Law article 19 and Rochester Local Law No. 6 of 1983, the Legislature enacted Real Property Tax Law article 19-A. The original law was found to violate equal protection by creating arbitrary tax distinctions based on location within Monroe County. Article 19-A shifted the responsibility for calculating tax rates from the county to the cities and towns within the county. Taxpayers continued to experience different county tax burdens based on their geographic location.

Procedural History

The Supreme Court, Monroe County, ruled in favor of the plaintiff challenging the constitutionality of Real Property Tax Law article 19-A. The City of Rochester appealed this decision to the Court of Appeals. The Court of Appeals affirmed the Supreme Court’s judgment, finding article 19-A unconstitutional.

Issue(s)

Whether Real Property Tax Law article 19-A violates the equal protection clauses of the Federal and State Constitutions by perpetuating arbitrary and invidious distinctions in county tax burdens based solely on geographic location.

Holding

Yes, because article 19-A continues to impose demonstrably different county tax burdens solely based on geographic location, failing to provide interjurisdictional equality between taxpayers in different assessing units, and thus violates the equal protection clauses of the Federal and State Constitutions.

Court’s Reasoning

The Court of Appeals relied heavily on its previous decision in Foss v. City of Rochester (65 NY2d 247), emphasizing the principle of stare decisis. The court found that while article 19-A shifted the responsibility for tax calculation, it did not cure the underlying constitutional defect identified in the original Foss case. Specifically, the court emphasized that the key problem – the imposition of demonstrably different county tax burdens based solely on geographic location – remained unaddressed. Article 19-A made no effort to provide equality between taxpayers in different assessing units. The court stated, “The imposition of demonstrably different county tax burdens, solely by reason of geographic location, continues unabated pursuant to chapter 828. Article 19-A makes no effort to provide interjurisdictional equality between taxpayers in different assessing units. (Foss v City of Rochester, 65 NY2d 247, 258-259, supra.)” Because the fundamental issue of geographic tax disparity persisted, the Court of Appeals felt compelled to declare article 19-A unconstitutional, adhering to the principles established in the prior Foss decision. The court’s decision underscores the importance of equal protection under the law and the impermissibility of arbitrary tax burdens based solely on location.