This case concerns unequal taxes on property.

In Pennsylvania, a county tax commissioner appraises land, meaning that he sets a value for the land, and the owner then pays real estate taxes based on that value. A commissioner valued land at its sales price, whenever it was sold. If land did not sell for many years, he made little or no adjustment in its appraised value. As a result, some property was assessed at 35 times as much as neighboring land. A corporate landowner sued. What constitutional issue is raised? What should the outcome be?