Earl B. Randolph v. Clyde H. Simpson

JOHN R. BROWN, Chief Judge:

This is an attack on the federal constitutional validity of the Florida ad valorem tax structure, which is established in her Constitution 1 and implementing statutes. The system is challenged primarily on the ground that the provisions for ad valorem taxation of real estate and tangible personal property by county and municipal governments at rates different from those imposed in ad valorem taxation of intangibles for the benefit of the State Government 2 result in a denial of equal protection of the laws. 3 The broad claim is made that the Federal Constitution…