Constitutional Law: Tax Assessments on Residential Health Care Facility's Gross Receipts for Medical Patient Care Declared Constitutional-Port Jefferson Health Care Facility V. Wing

By Burghardt, Heather N. | American Journal of Law & Medicine, January 1, 2000 | Go to article overview

Constitutional Law: Tax Assessments on Residential Health Care Facility's Gross Receipts for Medical Patient Care Declared Constitutional-Port Jefferson Health Care Facility V. Wing


Burghardt, Heather N., American Journal of Law & Medicine


Constitutional Law: Tax Assessments on Residential Health Care Facility's Gross Receipts For Medicaid Patient Care Declared Constitutional-Port Jefferson Health Care Facility v. Wing1-The Court of Appeals of New York held that a statutory scheme that assessed taxes on the gross receipts of residential health care facilities (RHCFs), while only allowing for reimbursement on the RHCF's Medicaid receipts, did not violate the equal protection clause.2 Plaintiffs, twenty-one for-profit RHCFs located in various parts of New York, brought this action against the State alleging that their equal protection rights were violated by this statutory tax scheme. Specifically, they alleged that the State extended its original 0.6% assessment on gross receipts of all RHCFs by imposing an "additional assessment" of 1.2% in 1992,3 and a "further additional assessment" of 3.8% in 1995,4 but only reimbursed RHCFs for taxes paid on receipts for Medicaid patient care. Plaintiffs claimed that this statutory tax scheme unconstitutionally discriminates against ltHCFs whose non-Medicaid patient population is larger that the Statewide average of twenty percent.5

The Michigan Supreme Court, in granting plaintiffs' motion for summary judgment, concluded that the State's interest in raising revenue without any further policy justification was inadequate because the gross receipts tax imposed the burden of the assessments more heavily upon some RHCFs than others. The Appellate Division affirmed, finding a disparity of taxation under the assessment and reimbursement scheme with RHCFs with a large proportion of gross receipts from non-Medicaid sources shouldering the financial burden for RHCFs with larger Medicaid populations. The court found that this disparate treatment resulted in a denial of equal protection not justified by the State's interest in raising revenue. The Court of Appeals reversed, however, declaring the tax assessment and reimbursement scheme constitutional.6

In applying equal protection review, the Court of Appeals first found a strong presumption of constitutionality for taxation classifications that the Plaintiffs had to overcome beyond a reasonable doubt. The court found that such assessments were subject to rational basis review. Furthermore, the court found that the standard in this case was especially deferential because it was being applied to the complex system of taxation where an equal protection violation will only amount from a difference in treatment that is "palpably arbitrary" or amounts to an "invidious discrimination."7

Even assuming that the taxation scheme created a "discrete and objectively identifiable class" triggering equal protection review, the court concluded that the scheme was rationally related to the goal of providing medical care for needy persons through the Medicaid system. The court followed the principle that a classification must be upheld against an equal protection challenge if there is any reasonably conceivable state of facts that could provide a rational basis for the classification. The court followed the United States Supreme Court's reasoning in its rejection of the equal protection challenge to California's Proposition Thirteen in Nordlinger v. …

The rest of this article is only available to active members of Questia

Sign up now for a free, 1-day trial and receive full access to:

  • Questia's entire collection
  • Automatic bibliography creation
  • More helpful research tools like notes, citations, and highlights
  • A full archive of books and articles related to this one
  • Ad-free environment

Already a member? Log in now.

Notes for this article

Add a new note
If you are trying to select text to create highlights or citations, remember that you must now click or tap on the first word, and then click or tap on the last word.
One moment ...
Default project is now your active project.
Project items

Items saved from this article

This article has been saved
Highlights (0)
Some of your highlights are legacy items.

Highlights saved before July 30, 2012 will not be displayed on their respective source pages.

You can easily re-create the highlights by opening the book page or article, selecting the text, and clicking “Highlight.”

Citations (0)
Some of your citations are legacy items.

Any citation created before July 30, 2012 will labeled as a “Cited page.” New citations will be saved as cited passages, pages or articles.

We also added the ability to view new citations from your projects or the book or article where you created them.

Notes (0)
Bookmarks (0)

You have no saved items from this article

Project items include:
  • Saved book/article
  • Highlights
  • Quotes/citations
  • Notes
  • Bookmarks
Notes
Cite this article

Cited article

Style
Citations are available only to our active members.
Sign up now to cite pages or passages in MLA, APA and Chicago citation styles.

(Einhorn, 1992, p. 25)

(Einhorn 25)

1

1. Lois J. Einhorn, Abraham Lincoln, the Orator: Penetrating the Lincoln Legend (Westport, CT: Greenwood Press, 1992), 25, http://www.questia.com/read/27419298.

Cited article

Constitutional Law: Tax Assessments on Residential Health Care Facility's Gross Receipts for Medical Patient Care Declared Constitutional-Port Jefferson Health Care Facility V. Wing
Settings

Settings

Typeface
Text size Smaller Larger Reset View mode
Search within

Search within this article

Look up

Look up a word

  • Dictionary
  • Thesaurus
Please submit a word or phrase above.
Print this page

Print this page

Why can't I print more than one page at a time?

Help
Full screen

matching results for page

    Questia reader help

    How to highlight and cite specific passages

    1. Click or tap the first word you want to select.
    2. Click or tap the last word you want to select, and you’ll see everything in between get selected.
    3. You’ll then get a menu of options like creating a highlight or a citation from that passage of text.

    OK, got it!

    Cited passage

    Style
    Citations are available only to our active members.
    Sign up now to cite pages or passages in MLA, APA and Chicago citation styles.

    "Portraying himself as an honest, ordinary person helped Lincoln identify with his audiences." (Einhorn, 1992, p. 25).

    "Portraying himself as an honest, ordinary person helped Lincoln identify with his audiences." (Einhorn 25)

    "Portraying himself as an honest, ordinary person helped Lincoln identify with his audiences."1

    1. Lois J. Einhorn, Abraham Lincoln, the Orator: Penetrating the Lincoln Legend (Westport, CT: Greenwood Press, 1992), 25, http://www.questia.com/read/27419298.

    Cited passage

    Thanks for trying Questia!

    Please continue trying out our research tools, but please note, full functionality is available only to our active members.

    Your work will be lost once you leave this Web page.

    For full access in an ad-free environment, sign up now for a FREE, 1-day trial.

    Already a member? Log in now.