Schuyler E. Cole, et al. v. City and County of Honolulu, Hawaii

This Court has held that the general constitutional requirement of the Equal Protection Clause, in relation to tax regulations, <is the seasonable attainment of a rough equality in tax treatment of similarly situated property owners.= Allegheny Pittsburgh Coal Co. v. Cnty. Comm’n of Webster Cnty., W. Va., 488 U.S. 336, 343, 109 S.Ct. 633, 638, 102 L.Ed.2d 688 (1989). The Question Presented is as follows: Whether a real property tax class that consists of certain residential properties that are distinguished from identical residential properties based solely on whether the properties have an assessed value of $1,000,000 or more, which results in different tax rates being charged on the first $999,999.99 of a property9s value, so that the owner of a property valued at $1,000,000 or more pays a higher tax rate on the first $999,999.99 of value than the owner of a property valued at $999,999.99 or less, amounts to unequal treatment rendering the tax classification unconstitutional under the Equal Protection Clause of the Fourteenth Amendment.