Duke Law School

Program in Public Law

Fitzgerald v. Racing Assoc. of Central Iowa

Iowa racetracks challenged legislation that significantly increased the state tax on racetracks, but not on riverboats. The state district court upheld the unequal taxing scheme, finding the state has a legitimate interest in promoting the riverboat industry and the economy of river towns. The Supreme Court of Iowa reversed, finding no rational basis for the differential tax treatment.

Question Presented:
Can the state of Iowa tax the revenue from slot machines at parimutuel racetracks and the revenue from all casino games on riverboats, including slot machines, at different rates without violating the Equal Protection Clause?

Decision under Review

Supreme Court Opinion