Armour v. City of Indianapolis

Armour v. City of Indianapolis
Supreme Court of the United States
Decided June 4, 2012
Full case name	Armour v. City of Indianapolis
Citations	566 U.S. 673 ( more )
Holding
Declining to refund people who had paid a lump sum instead of installments into a city program was rationally related to lowering administrative costs, so it did not violate the Equal Protection Clause.
Court membership
Chief Justice John Roberts Associate Justices Antonin Scalia  · Anthony Kennedy Clarence Thomas  · Ruth Bader Ginsburg Stephen Breyer  · Samuel Alito Sonia Sotomayor  · Elena Kagan
Case opinions
Majority	Breyer, joined by Kennedy, Thomas, Ginsburg, Sotomayor, Kagan
Dissent	Roberts, joined by Scalia, Alito
Laws applied
Equal Protection Clause

Armour v. City of Indianapolis, 566 U.S. 673(2012), was a United States Supreme Court case in which the court held that declining to refund people who had paid a lump sum instead of installments into a city program was rationally related to lowering administrative costs, so it did not violate the Equal Protection Clause. ^{[1] [2]}

Background

For decades, Indianapolis, Indiana funded sewer projects using Indiana's Barrett Law, which permitted cities to apportion a public-improvement project's costs equally among all abutting lots. Under that system, a city would create an initial assessment, dividing the total estimated cost by the number of lots and making any necessary adjustments. Upon a project's completion, the city would issue a final lot-by-lot assessment. Lot owners could elect to pay the assessment in a lump sum or over time in installments. ^[1]

After the City completed the Brisbane/Manning Sanitary Sewers Project, it sent affected homeowners formal notice of their payment obligations. Of the 180 affected homeowners, 38 elected to pay the lump sum. The following year, the City abandoned Barrett Law financing and adopted the Septic Tank Elimination Program (STEP), which financed projects partially through bonds, thereby lowering individual owner's sewer-connection costs. In implementing STEP, the City's Board of Public Works enacted a resolution forgiving all assessment amounts still owed pursuant to Barrett Law financing. Homeowners who had paid the Brisbane/Manning Project lump sum received no refund, while homeowners who had elected to pay in installments were under no obligation to make further payments. ^[1]

The 38 homeowners who paid the lump sum asked the City for a refund, but the City denied the request. Thirty-one of these homeowners brought suit in Indiana state court claiming that the City's refusal violated the Federal Equal Protection Clause. The trial court granted summary judgment to the homeowners, and the Indiana Court of Appeals affirmed. The Indiana Supreme Court reversed, holding that the City's distinction between those who had already paid and those who had not was rationally related to its legitimate interests in reducing administrative costs, providing financial hardship relief to homeowners, transitioning from the Barrett Law system to STEP, and preserving its limited resources. ^[1]

Opinion of the court

The Supreme Court issued an opinion on June 4, 2012. ^[1]

References

1. Armour v. City of Indianapolis, 566 U.S. 673 (2012).
2. Denniston, Lyle (June 4, 2012). "Opinion recap: Not so equal tax equality". SCOTUSblog. Retrieved October 11, 2025.

External links

• Text of Armour v. City of Indianapolis, 566 U.S. 673(2012) is available from: Justia

This article incorporates written opinion of a United States federal court. As a work of the U.S. federal government, the text is in the public domain .