Fitzgerald v. Racing Assn. of Cent. Iowa, 539 U.S. 103 (2003). · Go Syfert
Fitzgerald v. Racing Assn. of Cent. Iowa, 539 U.S. 103 (2003). Cases Citing This Book View Copy Cite
Quick Summary

The Equal Protection Clause is satisfied if there is a plausible policy reason for a classification and the relationship between the classification and the goal is not arbitrary.

After Iowa enacted legislation imposing different tax rates on slot machine revenues from riverboats and racetracks, respondents challenged the differential tax as a violation of the Equal Protection Clause. The question is whether a state's disparate tax rates for different gambling enterprises violate the Fourteenth Amendment. Applying rational-basis review, the Court holds that the Equal Protection Clause is satisfied if there is a plausible policy reason for the classification and the relationship between the classification and its goal is not so attenuated as to be arbitrary or irrational. Because the legislature may have rationally intended to support riverboat communities or protect riverboat operators, the differential tax is constitutional.

714 citation events (714 in the last 25 years) across 58 distinct courts.
Strongest positive: Lscp, Lllp v. Courtney M. Kay-Decker, Director, Iowa Department of Revenue (iowa, 2015-04-10)
Treatment trajectory · 2003 → 2026 · click a year to view as-of
2003 2014 2026
Top citers, strongest first. 50 distinct citers. How cited ↗
examined Cited as authority (verbatim quote) Lscp, Lllp v. Courtney M. Kay-Decker, Director, Iowa Department of Revenue (13×) also: Cited as authority (quoted), Cited "see"
Iowa · 2015 · quote attribution · 3 verbatim quotes · confidence high
in the end, we return to the fact that the item taxed - gambling revenue - is identical.
examined Cited as authority (verbatim quote) Amended June 12, 2015 LSCP, LLLP Vs. Courtney M. Kay-Decker, Director, Iowa Department of Revenue (12×) also: Cited as authority (quoted), Cited "see"
Iowa · 2015 · quote attribution · 3 verbatim quotes · confidence high
in the end, we return to the fact that the item taxed-gambling revenue-is identical.
examined Cited as authority (verbatim quote) Florida v. Powell (2×)
SCOTUS · 2010 · quote attribution · 2 verbatim quotes · confidence high
the iowa supreme court's opinion . . . says that 'iowa courts are to "apply the same analysis in considering the state equal protection clause as . . . in considering the federal equal protection claim
examined Cited as authority (quoted) City of Indianapolis v. Armour (10×) also: Cited "see"
Ind. · 2011 · quote attribution · 6 verbatim quotes · confidence low
the constitution grants legislators, not courts, broad authority (within the bounds of rationality) to decide whom they wish to help with their tax laws and how much help those laws ought to provide.
discussed Cited as authority (rule) VVF Intervest, L.L.C. v. Harris (2×) also: Cited "see"
Ohio · 2025 · confidence medium
Iowa Racing Assn., 539 U.S. 103, 108 (2003).
cited Cited as authority (rule) Danahy v. City of Chicago
N.D. Ill. · 2025 · confidence medium
Iowa, 539 U.S. 103, 108 (2003).
discussed Cited as authority (rule) King v. City of Chicago
N.D. Ill. · 2023 · confidence medium
The government satisfies its constitutional obligations “so long as there is a plausible policy reason for the classification … and the relationship of the classification to its goal is not so attenuated as to render the distinction arbitrary or irrational.” Fitzgerald v. Racing Ass’n of Central Iowa, 539 U.S. 103, 107 (2003) (quoting Nordlinger v. Hahn, 505 U.S. 1 , 11–12 (1992)).
cited Cited as authority (rule) BISER v. SLIPPERY ROCK UNIVERSITY
W.D. Pa. · 2023 · confidence medium
Iowa, 539 U.S. 103, 107 (2003)).
cited Cited as authority (rule) Christopher Ryan Allen v. State of Iowa
Iowa Ct. App. · 2022 · confidence medium
Iowa, 539 U.S. 103, 107 (2003) (alteration in original) (citation omitted).
cited Cited as authority (rule) Sassamansville Fire Company No. 1 v. Livelsberger
E.D. Pa. · 2022 · confidence medium
Iowa, 539 U.S. 103, 107 (2003)) (internal quotation marks omitted).
cited Cited as authority (rule) Sassamansville Fire Company No. 1 v. Livelsberger
E.D. Pa. · 2022 · confidence medium
Iowa, 539 U.S. 103, 107 (2003)) (internal quotation marks omitted).
cited Cited as authority (rule) Dipendra Tiwari v. Eric Friedlander
6th Cir. · 2022 · confidence medium
Iowa, 539 U.S. 103, 110 (2003), only to see the state courts grant relief for the same claim under the State’s Constitution, see Racing Ass’n of Cent.
cited Cited as authority (rule) Peter Vlaming v. West Point School Board
4th Cir. · 2021 · confidence medium
Fitzgerald v. Racing Ass’n of Central Iowa, 539 U.S. 103, 106 (2003).
discussed Cited as authority (rule) MAZO v. WAY
D.N.J. · 2021 · confidence medium
Iowa, 539 U.S. 103, 108 (2003) (“[That] the line might have been drawn differently . . . is a matter for legislative, rather than judicial, consideration.”); Trinsey v. Com. of Pa., 941 F.2d 224, 235 (3d Cir. 1991) (“We take no position on the balancing of the respective interests in this situation.
discussed Cited as authority (rule) Doe v. Lyft, Inc.
Ill. App. Ct. · 2020 · confidence medium
The Transportation Network Providers Act, “like most laws, might predominantly serve one general objective, *** while containing subsidiary provisions that seek to achieve other desirable (perhaps even contrary) ends as well, thereby producing a law that balances objectives but still serves the general objective when seen as a whole.” Fitzgerald v. Racing Ass’n of Central Iowa, 539 U.S. 103, 108 (2003).
discussed Cited as authority (rule) Doe v. Lyft, Inc.
Ill. App. Ct. · 2020 · confidence medium
The Transportation Network Providers Act, “like most laws, might predominantly serve one general objective, *** while containing subsidiary provisions that seek to achieve other desirable (perhaps even contrary) ends as well, thereby producing a law that balances objectives but still serves the general objective when seen as a whole.” Fitzgerald v. Racing Ass’n of Central Iowa, 539 U.S. 103, 108 (2003).
discussed Cited as authority (rule) Just Puppies, Inc.et al v. Frosh
D. Maryland · 2020 · confidence medium
Iowa, 539 U.S. 103, 109 (2003) (upholding state tax scheme favoring riverboat gambling over racetrack gambling); Nordlinger v. Hahn, 505 U.S. 1, 12 (1992) (upholding state property tax scheme favoring long term owners over new owners); Williamson v. Lee Optical of Okla.
cited Cited as authority (rule) Texas Democratic Party v. Greg Abbott, Gove
5th Cir. · 2020 · confidence medium
Iowa, 539 U.S. 103, 108 (2003).
discussed Cited as authority (rule) Just Puppies, Inc.et al v. Frosh
D. Maryland · 2020 · confidence medium
Iowa, 539 U.S. 103, 109 (2003) (upholding state tax scheme favoring riverboat gambling over racetrack gambling); Nordlinger v. Hahn, 505 U.S. 1, 12 (1992) (upholding state property tax scheme favoring long term owners over new owners); Williamson v. Lee Optical of Oklahoma Inc., 348 U.S. 483, 75 (1955) (upholding regulation permitting only licensed optometrists or ophthalmologists to fit lenses for eyeglasses).
discussed Cited as authority (rule) Lynchburg Range & Training, LLC v. Northam (2×)
W.D. Va. · 2020 · confidence medium
Fitzgerald v. Racing Ass’n of Central Iowa, 539 U.S. 103, 106 (2003).
discussed Cited as authority (rule) St. Joan Antida High School In v. Milwaukee Public School Distri (2×) also: Cited "see, e.g."
7th Cir. · 2019 · confidence medium
Iowa, 539 U.S. 103, 108 (2003); Regan, 461 U.S. at 550–51; Maher, 432 U.S. at 477 ; City of New Orleans v. Dukes, 427 U.S. 297 , 303–06 (1976) (per curiam); Dandridge v. Williams, 397 U.S. 471, 486 (1970) (per curiam).
examined Cited as authority (rule) St. Joan Antida High School In v. Milwaukee Public School Distri (4×) also: Cited "see, e.g."
7th Cir. · 2019 · confidence medium
Iowa, 539 U.S. 103, 108 (2003); Regan, 461 U.S. at 550–51; Maher, 432 U.S. at 477 ; City of New Orleans v. Dukes, 427 U.S. 297 , 303–06 (1976) (per curiam); Dandridge v. Williams, 397 U.S. 471, 486 (1970) (per curiam).
discussed Cited as authority (rule) Myron Dennis Behm, Burton J. Brooks, Bobby Lee Langston, David Leon Brodsky, Jeffrey R. Olson, and Geoff Tate Smith v. City of Cedar Rapids and Gatso USA, Inc. (2×)
Iowa · 2019 · confidence medium
Iowa, 539 U.S. 103, 110 , 123 S. Ct. 2156, 2161 (2003).
discussed Cited as authority (rule) Myron Dennis Behm, Burton J. Brooks, Bobby Lee Langston, David Leon Brodsky, Jeffrey R. Olson, and Geoff Tate Smith v. City of Cedar Rapids and Gatso USA, Inc. (2×)
Iowa · 2018 · confidence medium
Iowa, 539 U.S. 103, 110 , 123 S. Ct. 2156, 2161 (2003).
discussed Cited as authority (rule) Myron Dennis Behm, Burton J. Brooks, Bobby Lee Langston, David Leon Brodsky, Jeffrey R. Olson, and Geoff Tate Smith v. City of Cedar Rapids and Gatso USA, Inc. (2×)
Iowa · 2018 · confidence medium
Iowa, 539 U.S. 103, 110 , 123 S. Ct. 2156, 2161 (2003).
cited Cited as authority (rule) Monarch Beverage Co., Inc. v. Dale Grubb
7th Cir. · 2017 · confidence medium
Iowa, 539 U.S. 103, 107 (2003); Indiana Petroleum Marketers, 808 F.3d at 322 .
cited Cited as authority (rule) Karen Strehlke v. Grosse Pointe Pub. Sch. Sys.
6th Cir. · 2016 · confidence medium
Iowa, 539 U.S. 103, 108 (2003) (internal quotation marks omitted).
discussed Cited as authority (rule) Mary Hitchcock Mem. Hosp. v. Cohen
D.N.H. · 2016 · confidence medium
In summary, “[T]he Equal Protection Clause is satisfied so long as there is a plausible policy reason for the classification, the legislative facts on which the classification is apparently based rationally may have been considered to be true by the governmental decisionmaker, and the relationship of the classification to its goal is not so attenuated as to render the distinction arbitrary or irrational.” Fitzgerald v. Racing Ass’n of Central Iowa, 539 U.S. 103, 107 (2003) (quoting Nordlinger v. Hahn, 505 U.S. 1, 11-12 (1992)).
discussed Cited as authority (rule) Mary Hitchcock Mem. Hosp. v. Cohen, Secretary, Vermont Agency of Human Services, et al.
D.N.H. · 2016 · confidence medium
In summary, “[T]he Equal Protection Clause is satisfied so long as there is a plausible policy reason for the classification, the legislative facts on which the classification is apparently based rationally may have been considered to be true by the governmental decisionmaker, and the relationship of the classification to its goal is not so attenuated as to render the distinction arbitrary or irrational.” Fitzgerald v. Racing Ass’n of Central Iowa, 539 U.S. 103, 107 (2003) (quoting Nordlinger v. Hahn, 505 U.S. 1, 11-12 (1992)).
examined Cited as authority (rule) Sensational Smiles, LLC v. Jewel Mullen, Dr. (3×) also: Cited "see"
2d Cir. · 2015 · confidence medium
Id. at 105, 109 . 13 It may be that, as a practical matter, economic protectionism can be 14 couched in terms of some sort of alternative, indisputably legitimate state 15 interest.
cited Cited as authority (rule) Shimose v. Hawaii Health Systems Corporation dba Hilo Medical Center. ICA s.d.o., filed 11/20/2013 [ada], 131 Haw. 59. Petition for Writ of Certiorari, filed 01/21/2014.
Haw. · 2015 · confidence medium
Iowa, 539 U.S. 103, 106 (2003) (internal quotations and citation omitted).
examined Cited as authority (rule) Qwest Corp. v. Colorado Division of Property Taxation (4×) also: Cited "see"
Colo. · 2013 · confidence medium
Id. at 110, 123 S.Ct. 2156 .
examined Cited as authority (rule) Qwest Corporation v. Iowa State Board of Tax Review (14×) also: Cited "see"
Iowa · 2013 · confidence medium
Iowa, 539 U.S. 103, 107 , 123 S.Ct. 2156, 2159 , 156 L.Ed.2d 97, 103 (2003)] (requiring “ ‘a plausible policy reason for the classification’ ” (citation omitted)).
discussed Cited as authority (rule) Nextera Energy Resources LLC v. Iowa Utilities Board (2×)
Iowa · 2012 · confidence medium
Iowa, 539 U.S. 103, 110 , 123 S.Ct. 2156, 2161 , 156 L.Ed.2d 97, 105 (2003) (finding no violation of the Equal Protection Clause of the Federal Constitution when applying the traditional federal analytical framework), NextEra has failed to demonstrate a lack of factual basis for the asserted legitimate purposes.
discussed Cited as authority (rule) Rozanne E. King Alisha Jane King Dacie S. Houston, Individually and as Mother and Next Friend of Skylar Dwayne Ostrander, Chay Cortez Ostrander, and Adlia William Cortez Flood III Brandy R. Drake, Individually and as Mother and Next Friend of Logan Genner Luhmann, Susan Maule, Stephanie Maule, and Jacob Maule Michael Campbell, Individually and as Father and Next Friend of George Campbell and Soph (2×)
Iowa · 2012 · confidence medium
Iowa, 589 U.S. 103 , 110, 123 S.Ct. 2156, 2161 , 156 L.Ed.2d 97, 105 (2003) (deciding a constitutional claim in favor of the State after a motion for summary judgment); Vamum v. Brien, 763 N.W.2d 862, 907 (Iowa 2009) (deciding a statute was unconstitutional after developing the record in a summary judgment proceeding); Ames Rental Prop.
discussed Cited as authority (rule) State v. Bruegger (2×)
Iowa · 2009 · confidence medium
Iowa, 539 U.S. 103, 110 , 123 S.Ct. 2156, 2161 , 156 L.Ed.2d 97, 105 (2003).
cited Cited as authority (rule) State Of Iowa Vs. Jordan Kevin Lamar Bruegger
Iowa · 2009 · confidence medium
Iowa, 539 U.S. 103, 110 , 123 S. Ct. 2156, 2161 , 156 L.
cited Cited as authority (rule) Varnum v. Brien
Iowa · 2009 · confidence medium
Iowa, 539 U.S. 103, 107 , 123 S.Ct. 2156, 2159 , 156 L.Ed.2d 97, 103 (2003)).
discussed Cited as authority (rule) Rhodes v. State
Ga. · 2008 · confidence medium
Professors, 526 U. S. 124,127-128 (119 SC 1162, 143 LE2d 227) (1999); Barnett v. State, 270 Ga. 472, 472 ( 510 SE2d 527 ) (1999). 12 Fitzgerald v. Racing Assn. of Central Iowa, 539 U. S. 103,107 (123 SC 2156, 156 LE2d 97) (2003); Rouse v. Dept. of Nat.
cited Cited as authority (rule) Doe v. PA Bd Probation
3rd Cir. · 2008 · confidence medium
Iowa, 539 U.S. 103, 107 (2003)).
discussed Cited as authority (rule) Claude v. Guaranty National Insurance Co.
Iowa · 2004 · confidence medium
The rational basis test has been expressed as follows: “[T]he Equal Protection Clause is satisfied so long as there is a plausible policy reason for the classification, the legislative facts on which the classification is apparently based rationally may have been considered to be true by the governmental decisionmaker, and the relationship of the classification to its goal is not so attenuated as to render the distinction arbitrary or irrational.” Racing Ass’n v. Fitzgerald, 675 N.W.2d 1, 7 (Iowa 2004) (quoting Fitzgerald v. Racing Ass’n, 539 U.S. 103, 107 , 123 S.Ct. 2156, 2159 , 156 …
examined Cited as authority (rule) Racing Ass'n of Central Iowa v. Fitzgerald (53×) also: Cited "see"
Iowa · 2004 · confidence medium
Moreover, the claimed state interest must be “realistically conceivable.” Miller, 394 N.W.2d at 779 (emphasis added). 3 Our court must then decide whether this reason has a basis in fact. 4 See Fitzgerald, 539 U.S. at -, 123 S.Ct. at 2159 , 156 L.Ed.2d at 103 (requiring that legislature could rationally believe facts upon which classification was based are true).
discussed Cited "see" Haaayy, LLC v. Illinois Department of Financial & Professional Regulation
Ill. App. Ct. · 2024 · signal: see · confidence high
See Crusius v. Illinois Gaming Board, 216 Ill. 2d 315, 331-32 (2005) (“[Fitzgerald v. Racing Ass’n of Central Iowa, 539 U.S. 103 (2003), recognizes] the principle that, for purpose of rational basis review, not every provision in a law must share a single objective ***.”).
examined Cited "see" Sands Bethworks Gaming, LLC v. Pa. Dep't of Revenue (4×)
Pa. · 2019 · signal: see · confidence high
See id. at 109 , 123 S.Ct. at 2160 .
examined Cited "see" Hoesli v. Triplett, Inc. (3×)
Kan. · 2015 · signal: see · confidence high
See Fitzgerald v. Racing Ass’n of Central Iowa, 539 U.S. 103, 107 , 123 S. Ct. 2156 , 156 L.
discussed Cited "see" Sensational Smiles, LLC v. Mullen (2×)
2d Cir. · 2015 · signal: see · confidence high
See id. at 105 , 123 S.Ct. 2156 .
examined Cited "see" Heather Martin Gartner and Melissa Gartner, Individually and as Next Friends of Mackenzie Jean Gartner, a Minor Child v. Iowa Department of Public Health (3×)
Iowa · 2013 · signal: see · confidence high
See Racing Ass’n of Cent Iowa v. Fitzgerald, 648 N.W.2d 555, 563 (Iowa 2002), rev’d on other grounds, 539 U.S. 103 , 123 S.Ct. 2156 , 156 L.Ed.2d 97 (2003).
discussed Cited "see" City of Indianapolis v. Armour (2×)
Ind. Ct. App. · 2009 · signal: see · confidence high
See id. at 108 , 123 S.Ct. 2156 .
discussed Cited "see" Pheasant Run Condominium Homes Ass'n v. City of Brookfield (2×)
E.D. Wis. · 2008 · signal: see · confidence high
See Fitzgerald, 539 U.S. at 108 , 123 S.Ct. 2156 .
Retrieving the full opinion text from the archive…
FITZGERALD, TREASURER OF IOWA
v.
RACING ASSOCIATION OF CENTRAL IOWA Et Al.
02-695.
Supreme Court of the United States.
Jun 9, 2003.
539 U.S. 103
2003 U.S. LEXIS 4424
2003 Cal. Daily Op. Serv. 4841
Thomas J. Miller, Attorney General of Iowa, argued the cause for petitioner. With him on the briefs were Julie F Pottorff, Deputy Attorney General, and Jeffrey D. Farrell and Jean M. Davis, Assistant Attorneys General., Kent L. Jones argued the cause for the United States as amicus curiae urging reversal. With him on the brief were Solicitor General Olson, Assistant Attorney General O'Con-nor, David English Carmack, and Judith A. Hagley., Mark McCormick argued the cause for respondents. With him on the brief were Thomas L. Flynn, Edward M. Mansfield, Stephen C. Krumpe, and Lawrence P. McLellan.*
Breyer.
Cited by 147 opinions  |  Published
3 passages pin-cited by 3 cases
Pinpoint authority: bottom 90%
Citer courts: Indiana Supreme Court (6) · Supreme Court of Iowa (4)
[*105] Justice Breyer

delivered the opinion of the Court.

Iowa taxes adjusted revenues from slot machines on excursion riverboats at a maximum rate of 20 percent. Iowa Code § 99F.11 (2003). Iowa law provides for a maximum tax rate of 36 percent on adjusted revenues from slot machines at racetracks. §§99F.4A(6), 99F.11. The Iowa Supreme Court held that this 20 percent/36 percent difference in tax rates violates the Federal Constitution’s Equal Protection Clause, Amdt. 14, §1. 648 N. W. 2d 555 (2002). We disagree and reverse the Iowa Supreme Court’s determination.

I —

Before 1989, Iowa permitted only one form of gambling— parimutuel betting at racetracks — the proceeds of which it taxed at a six percent rate. Iowa Code § 99D.15 (1984). In 1989, it authorized other forms of gambling, including slot machines and other gambling games on riverboats, though it limited bets to $5 and losses to $200 per excursion. 1989 Iowa Acts ch. 67, §§ 3, 9(2); Iowa Code § 99F.3 (1996). Iowa taxed adjusted revenues from slot machine gambling at graduated rates, with a top rate of 20 percent. 1989 Iowa Acts ch. 67, §11; Iowa Code §99F.ll (1996).

In 1994, Iowa enacted a law that, among other things, removed the riverboat gambling $5/$200 bet/loss limits, 1994 Iowa Acts ch. 1021, §19, authorized racetracks to operate slot machines, § 13; Iowa Code §§99F.1(9), 99F.4A (1996), and imposed a graduated tax upon racetrack slot machine adjusted revenues with a top rate that started at 20 percent and would automatically rise over time to 36 percent, 1994 Iowa Acts ch. 1021, § 26; Iowa Code § 99F.11 (1996). The Act did not alter the tax rate on riverboat slot machine adjusted revenues, thereby leaving the existing 20 percent rate in place. Ibid.

Respondents, a group of racetracks and an association of dog owners, brought this lawsuit in state court challenging the 1994 legislation on the ground that the 20 percent/36 per[*106] cent tax rate difference that it created violated the Federal Constitution’s Equal Protection Clause, Amdt. 14, § 1. The State District Court upheld the statute. The Iowa Supreme Court disagreed and, by a 4-to-3 vote, reversed the District Court. The majority wrote that the “differential tax completely defeats the alleged purpose” of the statute, namely, “to help the racetracks recover from economic distress,” that there could “be no rational reason for this differential tax,” and that the Equal Protection Clause consequently forbids its imposition. 648 N. W. 2d, at 560-562. We granted cer-tiorari to review this determination.

II

Respondents initially claim that the Iowa Supreme Court’s decision rests independently upon state law. And they argue that this state-law holding bars review of the federal issue. We disagree. The Iowa Supreme Court’s opinion, after setting forth the language of both State and Federal Equal Protection Clauses, says that “Iowa courts are to ‘apply the same analysis in considering the state equal protection claims as ... in considering the federal equal protection claim.’” Id., at 558. We have previously held that, in such circumstances, we shall consider a state-court decision as resting upon federal grounds sufficient to support this Court’s jurisdiction. See Pennsylvania v. Muniz, 496 U. S. 582, 588, n. 4 (1990) (no adequate and independent state ground where the court says that state and federal constitutional protections are “ ‘identical’ ”). Cf. Michigan v. Long, 463 U. S. 1032, 1041-1042 (1983) (jurisdiction exists where federal cases are not “being used only for the purpose of guidance” and instead are “compel[ling] the result”). We therefore find that this Court has jurisdiction to review the Iowa Supreme Court’s determination.

III

We here consider whether a difference in state tax rates violates the Fourteenth Amendment’s mandate that “[nlo[*107] State shall. . . deny to any person ... the equal protection of the laws,” § 1. The law in question does not distinguish on the basis of, for example, race or gender. See, e. g., Loving v. Virginia, 388 U. S. 1 (1967); United States v. Virginia, 618 U. S. 516 (1996). It does not distinguish between instate and out-of-state businesses. See, e.g., Metropolitan Life Ins. Co. v. Ward, 470 U. S. 869 (1985). Neither does it favor a State’s long-time residents at the expense of residents who have more recently arrived from other States. Cf. Hooper v. Bernalillo County Assessor, 472 U. S. 612 (1985). Rather, the law distinguishes for tax purposes among revenues obtained within the State of Iowa by two enterprises, each of which does business in the State. Where that is so, the law is subject to rational-basis review:

“[T]he Equal Protection Clause is satisfied so long as there is a plausible policy reason for the classification, the legislative facts on which the classification is apparently based rationally may have been considered to be true by the governmental decisionmaker, and the relationship of the classification to its goal is not so attenuated as to render the distinction arbitrary or irrational.” Nordlinger v. Hahn, 505 U. S. 1, 11-12 (1992) (citations omitted).

See also id., at 11 (rational-basis review “is especially deferential in the context of classifications made by complex tax laws”); Allied Stores of Ohio, Inc. v. Bowers, 358 U. S. 522, 527 (1959) (the Equal Protection Clause requires States, when enacting tax laws, to “proceed upon a rational basis” and not to “resort to a classification that is palpably arbitrary”).

The Iowa Supreme Court found that the 20 percent/36 percent tax rate differential failed to meet this standard because, in its view, that difference “frustrated” what it saw as the law’s basic objective, namely, rescuing the racetracks from economic distress. 648 N. W. 2d, at 561. And[*108] no rational person, it believed, could claim the contrary. Id., at 561-562.

The Iowa Supreme Court could not deny, however, that the Iowa law, like most laws, might predominantly serve one general objective, say, helping the racetracks, while containing subsidiary provisions that seek to achieve other desirable (perhaps even contrary) ends as well, thereby producing a law that balances objectives but still serves the general objective when seen as a whole. See Railroad Retirement Bd. v. Fritz, 449 U. S. 166, 181 (1980) (Stevens, J., concurring in judgment) (legislation is often the “product of multiple and somewhat inconsistent purposes that led to certain compromises”). After all, if every subsidiary provision in a law designed to help racetracks had to help those racetracks and nothing more, then (since any tax rate hurts the racetracks when compared with a lower rate) there could be no taxation of the racetracks at all.

Neither could the Iowa Supreme Court deny that the 1994 legislation, seen as a whole, can rationally be understood to do what that court says it seeks to do, namely, advance the racetracks’ economic interests. Its grant to the racetracks of authority to operate slot machines should help the racetracks economically to some degree — even if its simultaneous imposition of a tax on slot machine adjusted revenues means that the law provides less help than respondents might like. At least a rational legislator might so believe. And the Constitution grants legislators, not courts, broad authority (within the bounds of rationality) to decide whom they wish to help with their tax laws and how much help those laws ought to provide. “The ‘task of classifying persons for . . . benefits ... inevitably requires that some persons who have an almost equally strong claim to favored treatment be placed on different sides of the line,’ and the fact the line might have been drawn differently at some points is a matter for legislative, rather than judicial, consideration.” Id., at 179 (citation omitted). See also ibid. (judicial review is “at[*109] an end” once the court identifies a plausible basis on which the legislature may have relied); Nordlinger, supra, at 17-18.

Once one realizes that not every provision in a law must share a single, objective, one has no difficulty finding the necessary rational support for the 20 percent/36 percent differential here at issue. That difference, harmful to the racetracks, is helpful to the riverboats, which, as respondents concede, were also facing financial peril, Brief for Respondents 8. See also 648 N. W. 2d, at 557. These two characterizations are but opposite sides of the same coin. Each reflects a rational way for a legislator to view the matter. And aside from simply aiding the financial position of the riverboats, the legislators may have wanted to encourage the economic development of river communities or to promote riverboat history, say, by providing incentives for riverboats to remain in the State, rather than relocate to other States. See Gaming Study Committee Report (Sept. 3, 1993), reprinted in App. 76-84, 86. Alternatively, they may have wanted to protect the reliance interests of riverboat operators, whose adjusted slot machine revenue had previously been taxed at the 20 percent rate. All these objectives are rational ones, which lower riverboat tax rates could further and which suffice to uphold the different tax rates. See Allied Stores, supra, at 528; Nordlinger, supra, at 12. See also Madden v. Kentucky, 309 U. S. 83, 88 (1940) (imposing burden on respondents to “negative every conceivable basis” that might support different treatment).

Respondents argue that Allegheny Pittsburgh Coal Co. v. Commission of Webster Cty., 488 U. S. 336 (1989), holds to the contrary. Brief for Respondents 21. In that case, the Court held that substantial differences in the level of property tax assessments that West Virginia imposed upon similar properties violated the Federal Equal Protection Clause. But the Court later stated, when it upheld in Nordlinger a California statute creating similar differences in property taxes, that “an obvious and critical factual difference be[*110] tween this case and Allegheny Pittsburgh is the absence of any indication in Allegheny Pittsburgh that the policies underlying an acquisition-value taxation scheme could conceivably have been the purpose for the ... unequal assessment.” 505 U. S., at 14-15. The Court in Nordlinger added that “Allegheny Pittsburgh was the rare case where the facts precluded any plausible inference that the reason for the unequal assessment practice was to achieve the benefits of an acquisition-value tax scheme.” Id., at 16-17, and n. 7. Here, “the facts” do not “preclud[e]” an inference that the reason for the different tax rates was to help the riverboat industry or the river communities. Id., at 16.

IV

We conclude that there is “a plausible policy reason for the classification,” that the legislature “rationally.may have . . . considered ... true” the related justifying “legislative facts,” and that the “relationship of the classification to its goal is not so attenuated as to render the distinction arbitrary or irrational.” Id., at 11. Consequently the State’s differential tax rate does not violate the Federal Equal Protection Clause. The Iowa Supreme Court’s judgment to the contrary is reversed, and the case is remanded for further proceedings not inconsistent with this opinion.

So ordered.