(Slip Opinion) OCTOBER TERM, 2007 1
Syllabus
NOTE: Where it is feasible, a syllabus (headnote) will be released, as is
being done in connection with this case, at the time the opinion is issued.
The syllabus constitutes no part of the opinion of the Court but has been
prepared by the Reporter of Decisions for the convenience of the reader.
See United States v. Detroit Timber & Lumber Co., 200 U. S. 321, 337.
SUPREME COURT OF THE UNITED STATES
Syllabus
CSX TRANSPORTATION, INC. v. GEORGIA STATE
BOARD OF EQUALIZATION ET AL.
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR
THE ELEVENTH CIRCUIT
No. 06–1287. Argued November 5, 2007—Decided December 4, 2007
Under Georgia law, most commercial and industrial property is valued
locally by county boards for tax purposes, but public utilities such as
petitioner railroad (CSX) are initially valued by the State. In 2002,
respondent Georgia state board used a different combination of
methodologies than it had in 2001 to determine that the market
value of CSX’s in-state real property had increased 47 percent, result
ing in a significantly higher ad valorem tax levy. CSX filed suit un
der the Railroad Revitalization and Regulatory Reform Act of 1976
(4–R Act or Act), which bars States from, inter alia, “[a]ssess[ing] rail
transportation property at a value that has a higher ratio to the
[property’s] true market value . . . than the ratio” between the as
sessed and true market values of other commercial and industrial
property in the same taxing jurisdiction, 49 U. S. C. §11501(b)(1), and
authorizes the federal district court to enjoin the tax if the railroad
ratio exceeds the ratio for other property by at least five percent,
§11501(c). CSX alleged that Georgia had grossly overestimated the
market value of its in-state rail property while accurately valuing
other commercial and industrial property in the State, so that CSX’s
property was taxed at a ratio of assessed-to-market value considera
bly more than 5 percent greater than the same ratio for the other in
state property. Ruling that Georgia had not discriminated against
CSX in violation of the 4–R Act because the State had used widely
accepted valuation methods to arrive at its 2002 estimate of true
market value, the District Court declared that the Act does not allow
a railroad to challenge a State’s chosen methodology if it is rational
and not motivated by discriminatory intent. The Eleventh Circuit
panel affirmed, reasoning that the Act does not clearly state that
2 CSX TRANSP., INC. v. GEORGIA STATE BD. OF
EQUALIZATION
Syllabus
railroads may challenge valuation methodologies, and that such a
clear statement was required in light of the intrusion on state taxing
prerogatives.
Held: The 4–R Act allows a railroad to attempt to show that state meth
ods for determining the value of railroad property result in a dis
criminatory determination of true market value. Pp. 5–12.
(a) The Act’s language is clear. States may not tax railroad prop
erty at a ratio of assessed-to-true-market value higher than the ratio
for other commercial and industrial property in the same jurisdiction.
To apply the Act, district courts must calculate the true market value
of in-state railroad property. A court cannot undertake the compari
son of ratios the statute requires without that figure at hand, see
Burlington Northern R. Co. v. Oklahoma Tax Comm’n, 481 U. S. 454,
461, and the determination of true market value may be affected by
the State’s choice of valuation methods. Georgia’s argument that
valuation methodologies must be distinguished from their applica
tion, and that the Act allows courts to question only the latter, is re
jected. There is no distinction between method and application in the
Act’s language and no passage limiting district court factfinding as
the State proposes. Georgia’s position is untenable given the way
market value is calculated. Valuation is not a matter of mathemat
ics, but an applied science, even a craft. Most appraisers estimate
market value by employing not one methodology but a combination
because no one approach is entirely accurate, at least in the absence
of an established market for the type of property at issue. The indi
vidual methods yield sometimes more, sometimes less reliable results
depending on the peculiar features of the property evaluated. Given
the extent to which the chosen methods can affect the determination
of value, preventing courts from scrutinizing state valuation method
ologies would render §11501 a largely empty command, forcing dis
trict courts to accept as “true” the market value estimate of the State,
one of the parties to the litigation. States, in turn, would be free to
employ appraisal techniques that routinely overestimate the market
worth of railroad assets. By then levying taxes based on those over
estimates, States could implement the very discriminatory taxation
Congress sought to eradicate. Courts would be powerless to stop
them, and the Act would ultimately guarantee railroads nothing
more than mathematically accurate discriminatory taxation.
The State’s warning that allowing railroads to introduce their own
valuation estimates based on different methodologies will inevitably
lead to a futile clash of experts, which courts will have no reasonable
way to settle, is not compelling, given that Congress was not simi
larly troubled. Rather, Congress directed courts to find true market
value, however elusive, making that value the objective benchmark
Cite as: 552 U. S. ____ (2007) 3
Syllabus
for courts’ evaluation. Property valuation, though admittedly com
plex, is at bottom just “an issue of fact about possible market prices,”
Suitum v. Tahoe Regional Planning Agency, 520 U. S. 725, 741, an is
sue district courts are used to addressing. In light of the statute’s di
rective making true market value a factual question to be determined
by the district court, what Georgia really seeks is to limit the types of
evidence courts may consider as part of their factual inquiry. Had
Congress intended to impose such a limit, it could easily have in
cluded language insulating the State’s chosen methodologies from ju
dicial scrutiny. It did not. Pp. 5–9.
(b) The State argues that any interpretation of the Act allowing
courts to question state valuation methods ignores the background
principles of federalism against which the statute was enacted. Even
if important state policy questions are intertwined with the selection
of a valuation methodology, however, Congress clearly permitted
courts to question such methodologies when it banned discriminatory
assessment ratios and made true market value a question to be liti
gated in federal court. Department of Revenue of Ore. v. ACF Indus
tries, Inc., 510 U. S. 332, 343–344, distinguished. The Court also dis
agrees with Georgia’s claim that the Court’s interpretation will
destroy the States’ discretion to choose their own valuation method
ologies. A State may use whatever method it likes, so long as the re
sult is not discriminatory in violation of the Act. Pp. 9–12.
472 F. 3d 1281, reversed.
ROBERTS, C. J., delivered the opinion for a unanimous Court.
Cite as: 552 U. S. ____ (2007) 1
Opinion of the Court
NOTICE: This opinion is subject to formal revision before publication in the
preliminary print of the United States Reports. Readers are requested to
notify the Reporter of Decisions, Supreme Court of the United States, Wash
ington, D. C. 20543, of any typographical or other formal errors, in order
that corrections may be made before the preliminary print goes to press.
SUPREME COURT OF THE UNITED STATES
_________________
No. 06–1287
_________________
CSX TRANSPORTATION, INC., PETITIONER v.
GEORGIA STATE BOARD OF
EQUALIZATION ET AL.
ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF
APPEALS FOR THE ELEVENTH CIRCUIT
[December 4, 2007]
CHIEF JUSTICE ROBERTS delivered the opinion of the
Court.
The Railroad Revitalization and Regulatory Reform Act
prohibits States from discriminating against railroads by
taxing railroad property more heavily than other commer
cial property in the State. Two decades ago, we held that
this statute permits an aggrieved railroad to challenge a
State’s valuation of its property for tax purposes. Burling
ton Northern R. Co. v. Oklahoma Tax Comm’n, 481 U. S.
454, 462 (1987). Because the railroad in that case chal
lenged only the State’s application of its valuation meth
ods, we expressly reserved the question whether a railroad
may challenge the State’s methods themselves. We an
swer that question today, and hold that railroads may
challenge state methods for determining the value of
railroad property, as well as how those methods are ap
plied. The statute provides for nothing less.
I
Congress enacted the Railroad Revitalization and Regu
2 CSX TRANSP., INC. v. GEORGIA STATE BD. OF
EQUALIZATION
Opinion of the Court
latory Reform Act in 1976. 90 Stat. 31.1 Called the “4–R
Act” for brevity, the law aimed to halt the economic de
cline of the rail industry by, among other means, barring
“discriminatory state taxation of railroad property.” Bur
lington Northern, supra, at 457; see also Department of
Revenue of Ore. v. ACF Industries, Inc., 510 U. S. 332, 336
(1994). The 4–R Act prohibits four separate forms of
discriminatory state taxation of railroads.2 Only the first
is at issue here: States, the Act provides, may not “[a]ssess
rail transportation property at a value that has a higher
ratio to the [property’s] true market value . . . than the
ratio” between the assessed and true market values of
other commercial and industrial property in the same
taxing jurisdiction. 49 U. S. C. §11501(b)(1). If the rail
road ratio exceeds the ratio for other property by at least
five percent, the district court may enjoin the tax.
——————
1 The portion of the Act that concerns us here, Section 306, was origi
nally codified at 49 U. S. C. §26c (1976 ed.). In 1978, Congress recodi
fied it at 49 U. S. C. §11503 (1976 ed., Supp. II). Congress recodified it
again in 1995, without substantive change, this time as §11501. For
convenience, all references to the statute are to the text of §11501.
2 Section 11501 reads, in relevant part:
“(b) The following acts unreasonably burden and discriminate
against interstate commerce, and a State, subdivision of a State, or
authority acting for a State or subdivision of a State may not do any of
them:
“(1) Assess rail transportation property at a value that has a higher
ratio to the true market value of the rail transportation property than
the ratio that the assessed value of other commercial and industrial
property in the same assessment jurisdiction has to the true market
value of the other commercial and industrial property.
“(2) Levy or collect a tax on an assessment that may not be made
under paragraph (1) of this subsection.
“(3) Levy or collect an ad valorem property tax on rail transportation
property at a tax rate that exceeds the tax rate applicable to commer
cial and industrial property in the same assessment jurisdiction.
“(4) Impose another tax that discriminates against a rail carrier
providing transportation subject to the jurisdiction of the Board under
this part.”
Cite as: 552 U. S. ____ (2007) 3
Opinion of the Court
§11501(c).3
Petitioner CSX Transportation, Inc., is a freight rail
carrier with multiple routes across the State of Georgia.
As a consequence, it is subject to Georgia’s ad valorem tax
on real property. Under Georgia law, most commercial
and industrial property is valued locally by county boards.
Public utilities such as railroads, however, are initially
valued by the State, which then certifies the proposed
valuations to the county boards for adoption or alteration.
In 2001, Georgia’s State Board of Equalization, a respon
dent here, put CSX’s ad valorem tax liability at $4.6 mil
lion. A year later, the State’s appraiser used a different
combination of methodologies to determine the market
——————
3 Section 11501(c) provides:
“Notwithstanding section 1341 of title 28 and without regard to the
amount in controversy or citizenship of the parties, a district court of
the United States has jurisdiction, concurrent with other jurisdiction of
courts of the United States and the States, to prevent a violation of
subsection (b) of this section. Relief may be granted under this subsec
tion only if the ratio of assessed value to true market value of rail
transportation property exceeds by at least 5 percent the ratio of
assessed value to true market value of other commercial and industrial
property in the same assessment jurisdiction. The burden of proof in
determining assessed value and true market value is governed by State
law. If the ratio of the assessed value of other commercial and indus
trial property in the assessment jurisdiction to the true market value of
all other commercial and industrial property cannot be determined to
the satisfaction of the district court through the random-sampling
method known as a sales assessment ratio study (to be carried out
under statistical principles applicable to such a study), the court shall
find, as a violation of this section—
“(1) an assessment of the rail transportation property at a value that
has a higher ratio to the true market value of the rail transportation
property than the assessed value of all other property subject to a
property tax levy in the assessment jurisdiction has to the true market
value of all other commercial and industrial property; and
“(2) the collection of an ad valorem property tax on the rail transpor
tation property at a tax rate that exceeds the tax ratio rate applicable
to taxable property in the taxing district.”
4 CSX TRANSP., INC. v. GEORGIA STATE BD. OF
EQUALIZATION
Opinion of the Court
value of CSX’s in-state property.4 The result was a signifi
cantly higher tax levy. The State estimated the railroad’s
2002 market value at approximately $7.8 billion, 472 F. 3d
1281, 1285 (CA11 2006), a 47 percent increase over the
previous year. That brought the assessed value of CSX’s
Georgia property to $514.9 million, for a final property tax
bill of $6.5 million. Brief for Petitioner 15.
CSX filed suit in the United States District Court for the
Northern District of Georgia, contending that the State’s
2002 tax assessment violated the 4–R Act. The railroad
alleged that Georgia had grossly overestimated the mar
ket value of its in-state property while accurately valuing
other commercial and industrial property in the State.
The result, according to CSX, was that its rail property
was taxed at a ratio of assessed-to-market value consid
erably more than 5 percent greater than the same ratio for
the other property in the State.
To make its case, CSX submitted the testimony of its
own expert appraiser, who relied on a combination of
valuation methods different from those used by the ap
praiser for Georgia. The CSX appraiser calculated the
2002 market value of the railroad’s property to be $6
billion, not the $7.8 billion figure used by the State. 472
F. 3d, at 1285–1286. CSX maintained that the state ap
praiser’s valuation methodologies were flawed, and urged
the District Court to accept the market value estimated by
its expert as more accurate.
——————
4 Georgia assesses public utilities using the “unit rule.” Under this
rule, “an appraiser first determines the value of all assets of an entity,
regardless of location,” then multiplies “by the percentage of the entity
located within [the State] to determine what portion of the value of the
company should be allocated to the state.” 472 F. 3d 1281, 1283 (CA11
2006). The parties agree the unit rule is the appropriate rule for
valuing CSX’s property. There are, however, numerous methods
available to value property under the unit rule, and many of these
methods themselves have multiple variations. See id., at 1284.
Cite as: 552 U. S. ____ (2007) 5
Opinion of the Court
The District Court refused to do so. Following a bench
trial, the court ruled Georgia had not discriminated
against CSX in violation of the 4–R Act because the State
had used widely accepted valuation methods to arrive at
its estimate of true market value. 448 F. Supp. 2d 1330,
1341 (ND Ga. 2005). In the judgment of the District
Court, the Act “does not generally allow a railroad to
challenge the state’s chosen methodology,” as long as the
State’s methods are rational and not motivated by dis
criminatory intent. Ibid.
A divided panel of the Court of Appeals for the Eleventh
Circuit affirmed. 472 F. 3d 1281 (2006). The majority
reasoned that the “text of the Act does not clearly state
that railroads may challenge valuation methodologies,”
and that such a clear statement was required in light of
the intrusion on state taxing prerogatives. Id., at 1289.
Judge Fay dissented. Id., at 1292. Recognizing the divi
sion on this question among the Circuits, compare Con
solidated Rail Corp. v. Hyde Park, 47 F. 3d 473, 481–482
(CA2 1995) (a railroad may challenge a State’s valuation
methodology), and Burlington Northern R. Co. v. Depart
ment of Revenue of Wash., 23 F. 3d 239, 240–241 (CA9
1994) (same), with Chesapeake Western Ry. v. Forst, 938 F.
2d 528, 531 (CA4 1991) (a railroad may not challenge a
State’s valuation methodology), and 472 F. 3d, at 1289
(decision below), we granted certiorari, 550 U. S. ___
(2007), and now reverse.
II
“[T]he language of §1150[1] plainly declares the con
gressional purpose.” Burlington Northern, 481 U. S., at
461. States may not tax railroad property at a ratio of
assessed-to-true-market value higher than the ratio for
other commercial and industrial property in the same
jurisdiction. In order to apply the Act, district courts must
calculate the true market value of in-state railroad prop
6 CSX TRANSP., INC. v. GEORGIA STATE BD. OF
EQUALIZATION
Opinion of the Court
erty. A court cannot undertake the comparison of ratios
the statute requires without that figure at hand. We said
as much in Burlington Northern: “It is clear from [the
Act’s] language that in order to compare the actual as
sessment ratios, it is necessary to determine what the
‘true market values’ are.” Ibid.
We do not see how a court can go about determining
true market value if it may not look behind the State’s
choice of valuation methods. Georgia insists there is a
clear and important distinction between valuation meth
odologies and their application. As the State would have
it, the statute allows courts to question only the latter.
We find no distinction between method and application in
the language of the Act, and see no passage limiting dis
trict court factfinding in the manner the State proposes.
The total lack of textual support for Georgia’s position is
not surprising. The dichotomy the State presses would
eviscerate the statute by forcing courts to defer to the
valuation estimate of the State, when discriminatory
taxation by States was the very evil the Act aimed to ban.
Georgia’s position is untenable given the way market
value is calculated. Valuation is not a matter of mathe
matics, as if the district court could prevent discrimina
tory taxation simply by doublechecking the State’s as
sessment equations. Rather, the calculation of true
market value is an applied science, even a craft. Most
appraisers estimate market value by employing not one
methodology but a combination. These various methods
generate a range of possible market values which the
appraiser uses to derive what he considers to be an accu
rate estimate of market value, based on careful scrutiny of
all the data available. Appraisal Institute, The Appraisal
of Real Estate 49 (12th ed. 2001).
Georgia’s appraiser in the instant case, for example,
used three different valuation techniques—the discounted
cashflow approach, a market multiple approach, and a
Cite as: 552 U. S. ____ (2007) 7
Opinion of the Court
stock and debt approach. He derived five values from
these three methods, ranging from $8.126 billion to
$12.346 billion. After selecting a number at the low end of
the range and then subtracting another $400 million to
account for intangible property not subject to ad valorem
taxation, he settled on $7.8 billion as his final estimate of
the true market value. 472 F. 3d, at 1284–1285.
Appraisers typically employ a combination of methods
because no one approach is entirely accurate, at least in
the absence of an established market for the type of prop
erty at issue. The individual methods yield sometimes
more, sometimes less reliable results depending on the
peculiar features of the property evaluated. As the varia
tion in the state appraiser’s market-value range reveals,
different methods can produce substantially different
estimates. W. Kinnard, Income Property Valuation: Prin
ciples and Techniques of Appraising Income-Producing
Real Estate 52 (1971).
Given the extent to which the chosen methods can affect
the determination of value, preventing courts from scruti
nizing state valuation methodologies would render §11501
a largely empty command. It would force district courts to
accept as “true” the market value estimated by the State,
one of the parties to the litigation. States, in turn, would
be free to employ appraisal techniques that routinely
overestimate the market worth of railroad assets. By then
levying taxes based on those overestimates, States could
implement the very discriminatory taxation Congress
sought to eradicate. On Georgia’s reading of the statute,
courts would be powerless to stop them, and the Act would
ultimately guarantee railroads nothing more than
mathematically accurate discriminatory taxation. We do
not find this interpretation compelling. Instead, we agree
with Judge Fay in dissent below: “Since the objective of
any methodology is a determination of true market value,
a railroad should be allowed to challenge the method[s]
8 CSX TRANSP., INC. v. GEORGIA STATE BD. OF
EQUALIZATION
Opinion of the Court
used [by the State] in an attempt to prove that the result
. . . was not the true market value of its property.” 472
F. 3d, at 1294.
The State agrees that it may not be possible to fix true
market value with any precision. But it draws a different
conclusion from this premise. Because any number of
estimates are plausible, Georgia argues, the court is as
likely to get an accurate result by verifying the application
of the State’s methods—so long as they are broadly rea
sonable—as it is by employing another method altogether.
The State warns that allowing railroads to introduce their
own valuation estimates based on different methodologies
will inevitably lead to a futile clash of experts, which
courts will have no reasonable way to settle. At least one
of the Courts of Appeals shares this concern. See Chesa
peake Western, 938 F. 2d, at 532 (“There is no absolute
way to test the assertions of competing valuations . . .”
(internal quotation marks and brackets omitted)).
Congress was not similarly troubled. It directed courts
to find true market value, however elusive. It made that
value the objective benchmark for courts’ evaluation of
state taxes on railroad property. True market value may
well not be a single, precise number, but Congress obvi
ously believed it was susceptible to judicial inquiry and
that some approximations were better than others.
Georgia’s grim prophecies notwithstanding, the inquiry
the statute mandates is not unfamiliar to courts. Valua
tion of property, though admittedly complex, is at bottom
just “an issue of fact about possible market prices,” Sui
tum v. Tahoe Regional Planning Agency, 520 U. S. 725,
741 (1997), an issue district courts are used to addressing.
Railroad property is not frequently sold, but “determina
tions of market value are routinely made in judicial pro
ceedings without the benefit of a market transaction.” Id.,
at 742. The District Court in this case made clear that it
knew how to find true market value: “In a more typical
Cite as: 552 U. S. ____ (2007) 9
Opinion of the Court
case, the court would look at both [the railroad expert’s]
appraisal and [the State’s] appraisal to determine the true
market value of [the railroad].” 448 F. Supp. 2d, at 1338,
n. 8. It refused to do so not because true market value is
inherently elusive, but because it believed the Act did not
allow it to question the State’s methods.
In light of the statute’s directive making true market
value a factual question to be determined by the district
court, what Georgia is really asking for is a limitation on
the types of evidence courts may consider as part of their
factual inquiry. If Congress had wanted to impose such a
limit by reserving to States the prerogative of selecting
which valuation methods may be used, it surely could
have done so. Out of deference to the States, for example,
§11501(c) provides that “[t]he burden of proof in determin
ing . . . true market value [shall be] governed by State
law.” Congress could easily have included similar lan
guage insulating the State’s chosen methodologies from
judicial scrutiny. It did not. Like Oklahoma’s argument
in Burlington Northern, Georgia’s position in this case
ultimately “depends upon the addition of words to a statu
tory provision which is complete as it stands.” 481 U. S.,
at 463. We decline to find distinctions in the statute
where they do not exist, especially where, as here, those
distinctions would thwart the law’s operation.
III
Considering the clarity of the statute, we are tempted to
leave the discussion at that. “When we find the terms of a
statue unambiguous, judicial inquiry is complete . . . .”
Rubin v. United States, 449 U. S. 424, 430 (1981). Geor
gia, however, lodges two objections to our interpretation,
each of which merits a reply. First, the State argues that
any interpretation of the Act allowing courts to question
state valuation methods ignores the background principles
of federalism against which the statute was enacted. The
10 CSX TRANSP., INC. v. GEORGIA STATE BD. OF
EQUALIZATION
Opinion of the Court
majority below expressed a similar concern. “The selec
tion of a valuation methodology,” it ruled, “is part of th[e]
fundamental power of a state [to tax],” 472 F. 3d, at 1288,
and should not be limited absent a clear statement from
Congress. We have long held that the means States adopt
to collect their taxes “should be interfered with as little as
possible.” Dows v. Chicago, 11 Wall. 108, 110 (1871). But
we are persuaded that allowing railroads to challenge a
State’s valuation methodologies has been clearly author
ized by the terms of the 4–R Act.
As an initial matter, we question Georgia’s contention
that its selection of valuation methodologies is an impor
tant state policy choice intimately connected to its tax
power. Georgia does not prescribe any particular method
ology as a matter of state law. Its appraisers use different
methodologies in different combinations, as they see fit.
See 472 F. 3d, at 1284–1285 (explaining that the state
appraiser employed multiple methods and selected a value
according to his best judgment). This suit, in fact, is the
result of an individual appraiser’s decision to employ a
different combination of assessment techniques than that
used by his immediate predecessors. The methods he
selected were his choice, not the dictate of any state stat
ute or regulation. Ibid.
But even if important questions of state policy are, as
the Eleventh Circuit believed, “intertwined with the selec
tion of a valuation methodology,” id., at 1288, judicial
scrutiny of those methodologies is authorized by the 4–R
Act’s clear command to find true market value. As we
explained above, the power to calculate true market value
necessarily includes the power to look behind a State’s
valuation methods. That the statute should vest this
authority in the Nation’s courts is hardly surprising, given
Congress’s conclusion that the States were assessing
railroad property unfairly.
Our decision in Department of Revenue of Ore. v. ACF
Cite as: 552 U. S. ____ (2007) 11
Opinion of the Court
Industries, Inc., 510 U. S. 332 (1994), is not to the con
trary. That case concerned a different provision of the 4–R
Act—namely, the command in §11501(b)(4) preventing a
State from “[i]mpos[ing] another tax that discriminates
against a rail carrier providing transportation” in the
taxing jurisdiction. This bar on facially discriminatory
taxes, we held, did not prevent a State from exempting
certain nonrailroad property from otherwise generally
applicable ad valorem taxes. ACF Industries, 510 U. S., at
343. At the time the 4–R Act was adopted, a majority of
States exempted one or more classes of business property
from ad valorem taxation, “including business inventories,
raw materials used in textile manufacturing, . . . and
mechanics tools,” to name just a few. Id., at 344. The
States had provided such property tax exemptions for
years. In the face of this widespread and historical prac
tice, we declined to read the 4–R Act to prohibit a type of
tax exemption the text did not expressly mention. Ibid.
By contrast, we pointedly noted that the Act “prohibit[s]
discriminatory tax rates and assessment ratios in no
uncertain terms . . . and set[s] forth precise standards for
judicial scrutiny of challenged rate and assessment prac
tices.” Id., at 343. Georgia’s claim that court review of
state valuation methodologies is not authorized by a clear
statement in the Act ignores the statute’s explicit prohibi
tion of discriminatory assessment ratios. A district court
cannot accurately calculate or compare those ratios with
out determining true market value. Congress clearly
permitted courts to question state valuation methodologies
when it banned discriminatory assessment ratios and
made true market value a question to be litigated in fed
eral court.
Georgia also protests that our interpretation will de
stroy the States’ discretion to choose their own valuation
methodologies. We disagree. A State may use whatever
method or methods it likes, so long as the result is not
12 CSX TRANSP., INC. v. GEORGIA STATE BD. OF
EQUALIZATION
Opinion of the Court
discriminatory. The Act does not prohibit the use of any
valuation methodology. It prohibits discrimination. Far
from requiring States to follow a particular method, we
hold only that nothing in the statute prevents a railroad
from attempting to show that the methods chosen by the
State result in a discriminatory determination of true
market value.
The judgment of the Court of Appeals for the Eleventh
Circuit is reversed.
It is so ordered.