Armour v. City of Indianapolis Case Brief

Facts of the Case

In accordance with state law, the city formerly assessed sewer-project costs against abutting properties and allowed the owners to make a lump sum payment or pay in installments. The city subsequently changed its assessment method to include issuance of bonds, and forgave future installment payments without providing similar relief to the owners who prepaid their assessments in full.


Does the filing of an affidavit of personal bias or personal prejudice require the judge in question to remove himself from the case?


“No. Justice Stephen G. Breyer, writing for a 6-3 majority, affirmed the Indiana court. The Supreme Court held that the distinction between homeowners who had paid the full amount and homeowners who had their balance forgiven had a rational relationship to the legitimate interest of reducing administrative costs. The Court used rational basis review because the classification between homeowners was not suspect and did not involve a fundamental right.Chief Justice John G. Roberts, Jr. dissented, writing that the extreme disparity in tax burdens between homeowners violated the equal protection clause under rational basis review. While administrative costs can play a role, they do not justify charging some taxpayers 30 times what other similarly situated taxpayers paid. Indianapolis even provided detailed records of how much each homeowner overpaid, so the only administrative cost would be cutting checks and mailing them to the homeowners. Justice Antonin Scalia and Justice Samuel A. Alito, Jr. joined in the dissent.”

Case Information

Citation: 566 US (2012)
Granted: Nov 14, 2011
Argued: Feb 29, 2012
Decided: Jun 4, 2012
Case Brief: 2012