OPINION
AMDAHL, Chief Justice.
Relators James and Ingrid Lund petition this court on writ of certiorari to review the decision of the Tax Court upholding an assessment of homestead property taxes on relators’ property. The Tax Court held that the statutory scheme for determining homestead property taxes is valid under the federal and state constitutions. We affirm.
The relevant facts are not in dispute. Relators own homestead property in Minneapolis. The county assessor valued rela-tors’ property at $148,800 as of January 2, 1983. Relators’ property was defined as class 3c property under Minn.Stat. § 273.-13, subd. 7 (1984).1 That statute provided in part:
[619]*619All * * * real estate * * * used for the purposes of a homestead, * * * shall be valued and assessed as follows: the first $30,000 of market value shall be assessed at 17 percent; the next $30,000 of market value shall be valued and assessed at 19 percent; and the remaining market value shall be valued and assessed at 30 percent. * * * The property tax to be paid on class 3c property * * shall be reduced by 54 percent of the tax imposed on the first $67,000 of market value. The amount of the reduction shall not exceed $650.
Relators’ property was taxed accordingly, including a reduction of $650 from the assessment, as statutorily provided. On appeal to this court, relators present several constitutional challenges to the homestead taxing scheme. Before addressing relators’ arguments, it is important to note the standard of review applied by this court. Where a party challenges a statute as unconstitutional, this court will not strike down the statute unless “the party challenging it demonstrates beyond a reasonable doubt that the statute violates some constitutional provision.” Miller Brewing Co. v. State, 284 N.W.2d 353, 356 (Minn.1979). As stated by the United States Supreme Court, “those challenging the legislative judgment must convince the court that the legislative facts on which the classification is apparently based could not reasonably be conceived to be true by the governmental decisionmaker.” Vance v. Bradley, 440 U.S. 93, 99 S.Ct. 939, 59 L.Ed.2d 171 (1979); see also Minnesota v. Clover Leaf Creamery Co., 449 U.S. 456, 464, 101 S.Ct. 715, 723, 66 L.Ed.2d 659 (1981). In the context of challenges to a state taxing scheme, the United States Supreme Court has been especially deferential. In San Antonio Indep. School Dist. v. Rodriguez, 411 U.S. 1, 93 S.Ct. 1278, 36 L.Ed.2d 16 (1973), the Court rejected an equal protection challenge against an ad valorem property tax to supplement educational financing. The Court stated:
No scheme of taxation, whether the tax is imposed on property, income, or purchases of goods and services, has yet been devised which is free of all discriminatory impact. In such a complex arena in which no perfect alternatives exist, the Court does well not to impose too rigorous a standard of scrutiny lest all local fiscal schemes become subjects of criticism under the Equal Protection Clause.”
411 U.S. at 41, 93 S.Ct. at 1301.
Relators challenge the taxing scheme under both the equal protection clause and article X, § 1 of the Minnesota Constitution, commonly known as the “Uniformity Clause.”2 We have determined that the state uniformity clause is no more restrictive upon the state legislature’s power to tax or classify than the federal equal protection clause, and that an analysis under equal protection is applicable to the state constitutional challenge. See, e.g., Hegenes v. State, 328 N.W.2d 719, 720-21 (Minn.1983); Matter of McCannell, 301 N.W.2d 910, 916 n. 4 (Minn.1980).
Relators argue first that the statute violated equal protection because it provided for homestead property to be assessed at different graduated rates, based on the estimated value of the house. We find that relators have not met the difficult burden of proof of showing that this scheme of taxation violated equal protection. In Apartment Operators Ass’n v. City of Minneapolis, 191 Minn. 365, 254 N.W. 443 (1934), we held a statute constitutional which gave tax preference to homesteads of $4,000 or less, determining that “ability to pay may properly be taken into consideration by the legislature in classifying property for the purpose of taxation.” Id. at 370, 254 N.W. at 445.
We hold that our decision in Apartment Operators is controlling on this issue. Re-lators provide no evidence showing that the legislature could not have reasonably determined that market value of property gives [620]*620some indication of the ability to pay, and accordingly decided to tax homesteads to reflect market values. In the absence of any such showing, we are compelled to reject relators’ argument.
Relators also challenge the homestead tax based on its distinction between owners and renters. Relators argue that creating a preference for an owner occupier over a renter occupier creates a preference and establishes an inequality. In Miller Brewing, this court enunciated the test to determine the constitutionality of statutory classifications:
(1) The distinctions which separate those included within the classification from those excluded must not be manifestly arbitrary or fanciful but must be genuine and substantial, thereby providing a natural and reasonable basis to justify legislation adapted to peculiar conditions and needs; (2) the classification must be genuine or relevant to the purpose of the law; that is, there must be an evident connection between the distinctive needs peculiar to the class and the prescribed remedy; (3) the purpose of the statute must be one that the state can legitimately attempt to achieve.
284 N.W.2d at 356.
In the present case, the preference given to homestead property “has a tendency to encourage the use of land for homestead purposes and is in furtherance of a sound public policy. The stability of government is promoted thereby.” Apartment Operators, 191 Minn. at 369, 254 N.W. at 445. The state may promote homestead ownership as a legitimate goal. To achieve this end, the legislature could have reasonably found that reduced tax liabilities for homestead owners encourages individuals to purchase homestead property and provided benefits to homeowners, who face greater maintenance costs and risk of substantial loss. The distinction between owner occupiers and renter occupiers is genuine, not fanciful, in light of the added responsibilities of homeowners and their different relation to the property from renters.3 These distinctions justify the different tax treatment between homestead owners and renters.4
Relators also argue that the taxing statute violates due process because it constitutes “special legislation” exempting property from taxation.
Free access — add to your briefcase to read the full text and ask questions with AI
OPINION
AMDAHL, Chief Justice.
Relators James and Ingrid Lund petition this court on writ of certiorari to review the decision of the Tax Court upholding an assessment of homestead property taxes on relators’ property. The Tax Court held that the statutory scheme for determining homestead property taxes is valid under the federal and state constitutions. We affirm.
The relevant facts are not in dispute. Relators own homestead property in Minneapolis. The county assessor valued rela-tors’ property at $148,800 as of January 2, 1983. Relators’ property was defined as class 3c property under Minn.Stat. § 273.-13, subd. 7 (1984).1 That statute provided in part:
[619]*619All * * * real estate * * * used for the purposes of a homestead, * * * shall be valued and assessed as follows: the first $30,000 of market value shall be assessed at 17 percent; the next $30,000 of market value shall be valued and assessed at 19 percent; and the remaining market value shall be valued and assessed at 30 percent. * * * The property tax to be paid on class 3c property * * shall be reduced by 54 percent of the tax imposed on the first $67,000 of market value. The amount of the reduction shall not exceed $650.
Relators’ property was taxed accordingly, including a reduction of $650 from the assessment, as statutorily provided. On appeal to this court, relators present several constitutional challenges to the homestead taxing scheme. Before addressing relators’ arguments, it is important to note the standard of review applied by this court. Where a party challenges a statute as unconstitutional, this court will not strike down the statute unless “the party challenging it demonstrates beyond a reasonable doubt that the statute violates some constitutional provision.” Miller Brewing Co. v. State, 284 N.W.2d 353, 356 (Minn.1979). As stated by the United States Supreme Court, “those challenging the legislative judgment must convince the court that the legislative facts on which the classification is apparently based could not reasonably be conceived to be true by the governmental decisionmaker.” Vance v. Bradley, 440 U.S. 93, 99 S.Ct. 939, 59 L.Ed.2d 171 (1979); see also Minnesota v. Clover Leaf Creamery Co., 449 U.S. 456, 464, 101 S.Ct. 715, 723, 66 L.Ed.2d 659 (1981). In the context of challenges to a state taxing scheme, the United States Supreme Court has been especially deferential. In San Antonio Indep. School Dist. v. Rodriguez, 411 U.S. 1, 93 S.Ct. 1278, 36 L.Ed.2d 16 (1973), the Court rejected an equal protection challenge against an ad valorem property tax to supplement educational financing. The Court stated:
No scheme of taxation, whether the tax is imposed on property, income, or purchases of goods and services, has yet been devised which is free of all discriminatory impact. In such a complex arena in which no perfect alternatives exist, the Court does well not to impose too rigorous a standard of scrutiny lest all local fiscal schemes become subjects of criticism under the Equal Protection Clause.”
411 U.S. at 41, 93 S.Ct. at 1301.
Relators challenge the taxing scheme under both the equal protection clause and article X, § 1 of the Minnesota Constitution, commonly known as the “Uniformity Clause.”2 We have determined that the state uniformity clause is no more restrictive upon the state legislature’s power to tax or classify than the federal equal protection clause, and that an analysis under equal protection is applicable to the state constitutional challenge. See, e.g., Hegenes v. State, 328 N.W.2d 719, 720-21 (Minn.1983); Matter of McCannell, 301 N.W.2d 910, 916 n. 4 (Minn.1980).
Relators argue first that the statute violated equal protection because it provided for homestead property to be assessed at different graduated rates, based on the estimated value of the house. We find that relators have not met the difficult burden of proof of showing that this scheme of taxation violated equal protection. In Apartment Operators Ass’n v. City of Minneapolis, 191 Minn. 365, 254 N.W. 443 (1934), we held a statute constitutional which gave tax preference to homesteads of $4,000 or less, determining that “ability to pay may properly be taken into consideration by the legislature in classifying property for the purpose of taxation.” Id. at 370, 254 N.W. at 445.
We hold that our decision in Apartment Operators is controlling on this issue. Re-lators provide no evidence showing that the legislature could not have reasonably determined that market value of property gives [620]*620some indication of the ability to pay, and accordingly decided to tax homesteads to reflect market values. In the absence of any such showing, we are compelled to reject relators’ argument.
Relators also challenge the homestead tax based on its distinction between owners and renters. Relators argue that creating a preference for an owner occupier over a renter occupier creates a preference and establishes an inequality. In Miller Brewing, this court enunciated the test to determine the constitutionality of statutory classifications:
(1) The distinctions which separate those included within the classification from those excluded must not be manifestly arbitrary or fanciful but must be genuine and substantial, thereby providing a natural and reasonable basis to justify legislation adapted to peculiar conditions and needs; (2) the classification must be genuine or relevant to the purpose of the law; that is, there must be an evident connection between the distinctive needs peculiar to the class and the prescribed remedy; (3) the purpose of the statute must be one that the state can legitimately attempt to achieve.
284 N.W.2d at 356.
In the present case, the preference given to homestead property “has a tendency to encourage the use of land for homestead purposes and is in furtherance of a sound public policy. The stability of government is promoted thereby.” Apartment Operators, 191 Minn. at 369, 254 N.W. at 445. The state may promote homestead ownership as a legitimate goal. To achieve this end, the legislature could have reasonably found that reduced tax liabilities for homestead owners encourages individuals to purchase homestead property and provided benefits to homeowners, who face greater maintenance costs and risk of substantial loss. The distinction between owner occupiers and renter occupiers is genuine, not fanciful, in light of the added responsibilities of homeowners and their different relation to the property from renters.3 These distinctions justify the different tax treatment between homestead owners and renters.4
Relators also argue that the taxing statute violates due process because it constitutes “special legislation” exempting property from taxation. We have determined that a statute is invalid as special legislation if it arbitrarily classifies subjects or if it does not “include and operate uniformly upon all [members] of the class. * * *.” Duluth Banking Co. v. Koon, 81 Minn. 486, 490, 84 N.W. 335, 337 (1900). In the present case, we have already determined that the classification of homestead property is valid. The remaining issue is whether the statute taxed all members of each class under a uniform scheme. Rela-tors have not provided any showing that members of the same class who are similarly situated are treated differently. We therefore find that relators have not shown beyond a reasonable doubt that Minn.Stat. § 273.13 violates due process.
Relators next argue that the reduction in taxes for homestead owners is an exemption and is invalid because exemptions from taxation may only be made by constitutional amendment. In Elwell v. County of Hennepin, 301 Minn. 63, 221 N.W.2d 538 (1974), this court addressed the validity of Minn.Stat. § 273.111, referred to as the “green acres statute,” which provides a reduced tax assessment for agri[621]*621cultural land “determined solely with reference to [the property’s] appropriate agricultural classification and value * * Section 273.111, subd. 4 (1986). Appellant Hennepin County argued that the valuation method under the green acres statute was unconstitutional because it was not specifically authorized. This court determined that the statute was not an exemption statute but a classification statute and that the tax reduction under the green acres statute was proper if the classification of property was reasonable. Id. at 74-75, 221 N.W.2d at 546. In the present case, we have determined that the homestead classification is valid. We thus conclude that the challenged legislation is not an invalid exemption statute but instead a statute which reasonably classifies property.
Relators also challenge the use of general revenue funds to replace homestead tax reductions. Minn.Stat. § 273.13, subd. 15a (1984), provided for payment from the general fund for the purpose of replacing revenue lost as a result of the reduction in property taxes provided under subdivisions 6, 7, and 14a of the statute. Relators argue that such use of general revenue funds is improper. We disagree.
In Village of Burnsville v. Onischuk, 301 Minn. 137, 222 N.W.2d 523 (1974), appeal dismissed, 420 U.S. 916, 95 S.Ct. 1109, 43 L.Ed.2d 388 (1975), we determined whether Minn.Stat. ch. 473F (1974), the “Metropolitan Fiscal Disparities Act,” violated the state constitution. Chapter 473F pooled commercial property taxes collected in a seven-county area and redistributed them in a manner which provided more funds to areas with less commercial development than had been collected from them. We found the statute did not violate the state constitutional requirement for uniformity of taxes. Id. at 153-54, 222 N.W.2d at 532-33.
Applied to the taxing scheme at issue, Onischuk indicates that distribution of general revenue funds in varying amounts as credits to homeowners does not violate the uniformity clause of the state constitution. Relators provide no other showing that the use of general revenue funds to promote homeownership is constitutionally improper.5 We therefore hold that Minn. Stat. § 273.13, subd. 15a, validly provided for use of general revenue funds to replace amounts reduced by the homeowners’ exemption.
Finally, we are presented with the issue of whether there is some limit on the amount at which property may be taxed. For example, could the state tax a $100,000 piece of property at the rate of $100,000 per year? We need not determine what, if any, upper limit exists on property taxes. In the present case, the record indicates that relators’ property was taxed at approximately 4.9%. This rate of taxation is clearly not excessive.
In summary, we hold that relators have not shown beyond a reasonable doubt that the homestead property taxing scheme violates either the state or federal constitution.
Affirmed.