The following summary is based on an opinion of the U.S. District Court for the District of New Hampshire. Federal district court cases apply federal law and sometimes New Hampshire law. Their interpretations of New Hampshire law are not binding on the New Hampshire Supreme Court.
The City funded sewer projects using special assessments of benefits on the benefited properties. Lot owners were allowed to pay in a lump sum or in installments over time. Of 180 affected properties, 38 elected to pay the lump sum. The following year the City adopted an entirely different method to finance the project through bonds instead of the special assessments. The City forgave the unpaid installment payments but refused to refund the lump sum payments it had already received. The lot owners who had paid the lump sums sued the City, claiming violation of their Fourteenth Amendment right to equal protection of the laws. The Indiana Supreme Court upheld the City's decision, and the U.S Supreme Court agreed to hear the case by writ of certiorari.
Classifications in taxation will be upheld under the Equal Protection Clause as long as "there is any reasonably conceivable state of facts that could provide a rational basis for the classification." The City argued that, after switching financing methods, either continuing with collection of the special assessments or processing refunds would have been complex, expensive and burdensome for many years. "Administrative concerns" generally suffice to justify the classifications made in taxation cases, and the Supreme Court upheld the City's action by a vote of 6-3.