Acf Industries, Incorporated v. The State of Arizona and Arizona Department of Revenue

Eleven companies that own and lease railroad cars to operating carriers (the “Carlines”) appeal a district court decision 561 F.Supp. 595 which upheld' the State of Arizona in an action challenging Arizona’s assessment of ad valorem taxes. We affirm.

The Carlines and Arizona agree that 49 U.S.C. § 11503(b)(1) forbids assessing Car-lines’ property at an assessment ratio exceeding the “average assessment ratio” applicable to all “other commercial and industrial property in the assessment jurisdiction.” They disagree about what this language means.

The Carlines’ first claim is that the state ought…