dissenting.
Vietnam veterans are, of course, a distinct minority of the population of New Mexico.1 The majority has decided to *625provide them with a special benefit that is not available to the average citizen. In my opinion, there can be no question about the constitutionality of that decision, and I believe it is equally clear that there is nothing invidious in the way the State has defined the class of veterans eligible for the benefit. The validity of the classification is unaffected by the form of the benefit or the date of enactment of the statute. It does not violate the Equal Protection Clause of the Fourteenth Amendment.
I
The New Mexico legislation that is challenged in this case provides a $2,000 property tax exemption to Vietnam veterans (or their unmarried surviving spouses) if the veteran was, among other requirements, a New Mexico resident prior, to May 8, 1976.2 N. M. Stat. Ann. §7-37^5(0 (1983). This 'legislation is consistent wdth the Equal Protection Clause if “the distinction it makes rationally furthers a legitimate state purpose.” Zobel v. Williams, 457 U. S. 55, 60 (1982).
Arguably, this statute raises two questions under the Equal Protection Clause: (1) is there a rational justification for treating the eligible veterans more favorably than the average citizen; and (2) if so, is there any rational justification *626for not offering the benefit to all veterans who then lived, or might thereafter live, in New Mexico?
The justification for providing a special benefit for veterans, as opposed to nonveterans, has been recognized throughout the history of our country. It merits restatement. First, the simple interest in expressing the majority’s gratitude for services that often entail hardship, hazard, and separation from family and friends, and that may be vital to the continued security of our Nation, is itself an adequate justification for providing veterans with a tangible token of appreciation. Second, recognition of the fact that military service typically disrupts the normal progress of civilian employment justifies additional tangible benefits — employment preferences, educational opportunities, subsidized loans, tax exemptions, or cash bonuses — to help overcome the adverse consequences of service and to facilitate the reentry into civilian society. A policy of providing special benefits for veterans’ past contributions has “always been deemed to be legitimate.”3
The historic justification would support a state decision to provide a benefit for all Vietnam veterans.4 This case, however, involves a challenge to a decision to provide a benefit *627for some, but not all, veterans residing in New Mexico. What is the justification for placing any limit on the class of eligible veterans? The most obvious answer is that the State’s resources are not infinite. The need to budget for the future is itself a valid reason for concluding that a limit should be placed on the size of the class of potential beneficiaries. And surely that limit may be defined in a way that is intended to direct finite state resources to those who may have a special need.
In this case, New Mexico’s legislation reflects, not only an expression of gratitude, but also an attempt to ameliorate the hardship Vietnam veterans experienced upon seeking to integrate or reintegrate themselves into New Mexican society. The transition from military to civilian life has always been a difficult one. That transition is furthered by a state decision to provide a benefit for those veterans who once had roots in the State and had returned, or decided to settle in the State, after their military service ended. New Mexico’s modest monetary benefit can be reasonably understood as both a tangible and symbolic “welcome home” to veterans returning to New Mexico from the Far East as well as to those deciding to establish their domiciles in the State for the first time. The legislation simply reflects and recognizes the State’s felt obligation to facilitate the difficult transition of veterans from the battlefields of Asia to civilian life in New Mexico.
Of course, the legislature might have crafted a more elaborate set of eligibility criteria, but since exclusion from the favored class merely places the ineligible veteran in the same class as the majority of the citizenry, there is no constitutional objection to the use of a simple, easily administered standard. The statutory requirement of residence before May 8,1976, is not a perfect proxy for identifying those Vietnam veterans seeking admission or readmission into New Mexican society, but “rational distinctions may be made with substantially less than mathematical exactitude.” New Orleans v. Dukes, 427 U. S. 297, 303 (1976).
*628HH HH
In my opinion, the validity of the State’s classification is not undermined by the fact that it takes the form of a modest annual tax exemption instead of a cash payment or gold medal. It is true that the continuing character of the exemption differentiates the eligible veteran from the rest of the citizenry over an extended period of time, but I fail to see how that fact bears on the rationality of the classification. If New Mexico had awarded gold medallions to all of its resident veterans on May 1, 1976, I believe it would be absurd for a veteran arriving in the State in 1981 to claim that he or she had a constitutional right either to a comparable medal or to have all other medal recipients return them to the State.
In like manner, New Mexico by this legislation has provided, in effect, a modest annuity for veterans who own real property. Again, it is surely rational'for the State to provide this form of assistance rather than a lump-sum cash bonus. To begin with, a one-time cash bonus would concentrate the fiscal burden of the veterans benefit in one budget year, perhaps preventing New Mexico from awarding any meaningful veterans benefit at all.5 Rather than providing a trivial token of esteem, the State may have decided to provide an annual and therefore recurring benefit which would, over time, amount to a more significant recognition of service to. returning veterans. The perennial character of its tax exemption may have been especially important in the minds of New Mexico’s legislators if their objective was to provide a symbolic expression of New Mexico’s invitation to rejoin the community on a long-term basis: The recurring form of the benefit provided symbolic reassurance of state support year *629after year. In so doing, the State might sensibly have expected to instill in returning Vietnam veterans a sense of security and peace of mind after the tumult of that conflict.
For these reasons, New Mexico’s statute is not at all like the Alaska dividend program struck down in Zobel v. Williams, 457 U. S. 55 (1982). The dividend program involved in Zobel created “an ever-increasing number of perpetual classes of concededly bona fide residents, based on how long they have been in the State.” Id., at 59. Every recent arrival was treated less favorably than those who had arrived earlier. The vast majority of dividend recipients were thus treated more favorably than the newly arrived minority. In this case, in contrast, the alleged victim of the discrimination is being treated exactly like the vast majority of New Mexico’s residents. In Zobel, the program had no rational justification other than a purpose to allocate a cash surplus among the majority of the citizenry on the basis of the duration of their residence in the State. In this case, the duration of the veteran’s residence is irrelevant and the distribution to the members of the favored class is supported by a legitimate state interest.6 There is a world of difference between a decision to provide benefits to some, but not all, veterans and a decision to divide the entire population into a multitude *630of classes differentiated only by length of residence. The State’s refusal to provide appellant with a veteran’s benefit has not branded him with any badge of inferiority. He has not been treated as a “second class citizen” in any sense. Rather, he has merely received precisely the same treatment as the vast majority of the residents of New Mexico.
f — I HH HH
The Court finds constitutionally significant the fact that the May 8, 1976, cut-off date was not enacted until 1983,7 and in its understanding of the application of the statute to a veteran who had merely resided in New Mexico as an infant. See ante, at 622. Neither point is valid.
Tellingly, the initial version of New Mexico’s property tax exemption for Vietnam-era veterans — which was enacted in 1973 — had an effective date of January 1, 1975. Even if the Court’s concern with “retroactive apportionment of an economic benefit,” ante, at 623, were valid — and the constitutional defect in retroactivity is never explained — the originating legislation simply was not retroactive.8 Thus, the Court’s point at best is limited to the state legislature’s decision on two subsequent occasions to liberalize the statutory requirements by extending the cut-off date for eligibility. But the Court does not — and cannot — explain why New *631Mexico’s belated recognition that its veterans’ assistance program was incomplete9 renders it ipso facto unconstitutional.
Even if New Mexico’s action were wholly retroactive I would find no constitutional defect. The New Mexico Legislature could reasonably conclude that for many Vietnam veterans the transition from military service to civilian life in New Mexico was still incomplete. New Mexico could further reasonably conclude that some assistance, at once tangible and symbolic, was required to complete the task. I do not think it unconstitutional for New Mexico to presume that Vietnam veterans who arrived in that State more than a year after the end of the Vietnam epoch had successfully readjusted to civilian life in a sister State prior to migrating to New Mexico.10 Under this view, appellant simply was not in New Mexico when the conditions justifying the assistance were deemed to exist. The late-arriving Vietnam veteran is treated as well as the overwhelming majority of immigrants to the State; until today’s decision, I would not have thought that the Constitution required New Mexico to do more.
In an attempt to highlight the asserted irrationality of the New Mexico statute, the Court asserts that an unquantifiable few late-in-coming Vietnam veterans might qualify for the property tax exemption:
“[T]he veteran who resided in New Mexico as an infant long ago would immediately qualify for the exemption upon settling in the State at any time in the future *632regardless of where he resided before, during, or after military service.” Ante, at 622.
The New Mexico Court of Appeals, however, did not adopt this construction of the statute: it did not reach this state-law question because appellant did not have standing to raise it.11 There is thus nothing in the record to support the Court’s assumption that if a veteran who resided in New Mexico as an infant should now return to the State, he or she would qualify for the tax exemption. It hardly befits a federal court that is committed to a policy of avoiding constitutional questions whenever possible to volunteer an unnecessary interpretation of a state statute in order to create a constitutional infirmity. But there is a more fundamental defect in the Court’s argument — indeed, in its entire analysis.
Even if there are a few isolated cases in which the general classification produces an arbitrary result, that is surely not a sufficient reason for concluding that the entire statute is unconstitutional:
"The mere fact that an otherwise valid general classification appears arbitrary in an isolated case is not a sufficient reason for invalidating the entire rule. Nor, indeed, is it a sufficient reason for concluding that the application of a valid rule in a hard case constitutes a *633violation of equal protection principles. We cannot test the conformance of rules to the principle of equality simply by reference to exceptional cases.” Caban v. Mohammed, 441 U. S. 380, 411-412 (1979) (Stevens, J., dissenting) (footnotes omitted).
See also Vance v. Bradley, 440 U. S. 93, 108 (1979); Califano v. Jobst, 434 U. S. 47, 56-58 (1977); Dandridge v. Williams, 397 U. S. 471, 485 (1970).
New Mexico has elected to express its gratitude to the veterans of the Vietnam conflict by providing a modest tax exemption for those who resided in the State before May 8, 1976. Those veterans who arrived thereafter are treated exactly like the nonveterans who constitute the majority of the State’s population. In my opinion, there is no substance to the claim that this classification violates the principle of equality embodied in the Equal Protection Clause of the Fourteenth Amendment to the Constitution.12
Accordingly, I respectfully dissent.
Approximately 55,000 Vietnam veterans reside in New Mexico. U. S. Dept, of Commerce, Bureau of the Census, Statistical Abstract of the United States 1985, p. 346 (105th ed. 1984) (estimate as of 1983), accounting for little more than 3.9% of the population. See id., at 11. Veterans as a whole comprise less than 11.6% of New Mexico’s residents. See id., at 11, 346.
The legislation is the product of four separate enactments. See ante, at 614-615, n. 2. In 1973, the New Mexico Legislature decided to grant a $2,000 property tax exemption to Vietnam veterans who had entered the Armed Forces from New Mexico and had been awarded a campaign medal for service in Vietnam. 1973 N. M. Laws, ch. 258, p. 1052. On three occasions after the original benefit was authorized, the New Mexico Legislature decided to enlarge the class of eligible beneficiaries. In 1975, it eliminated the requirement of a campaign medal 'for service in Vietnam, 1975 N. M. Laws, ch. 3, p. 11, and in 1981, it eliminated the requirement of residence at the time of enlistment and substituted a requirement of residence prior to May 8,1975,1981N. M. Laws, ch. 187, p. 1078, the last day of the “Vietnam era” as proclaimed by President Ford. Presidential Proclamation No. 4373, 3A CFR 48 (1975). In 1983, it extended eligibility to veterans who had been residents before May 8, 1976. 1983 N. M. Laws, eh. 330, p. 2112.
“Veterans have ‘been obliged to drop their own affairs to take up the burdens of the nation,’ Boone v. Lightner, 319 U. S. 561, 575 (1943), ‘ “subjecting themselves to the mental and physical hazards as well as the economic and family detriments which are peculiar to military service and which do not exist in normal civil life.” ’ Johnson v. Robison, 415 U. S. 361, 380 (1974) (emphasis deleted). Our country has a longstanding policy of compensating veterans for their past contributions by providing them with numerous advantages. This policy has ‘always been deemed to be legitimate.’ Personnel Administrator of Mass. v. Feeney, 442 U. S. 256, 279, n. 25 (1979).” Regan v. Taxation with Representation of Wash., 461 U. S. 540, 550-551 (1983) (footnote omitted).
Although the Court’s opinion is ambiguous on this point, see ante, at 620, I do not understand it to invalidate laws limiting benefits to veterans who resided in the State immediately prior to induction.
After World War II, for example, the legislature decided to extend a property tax exemption to veterans of that war because it felt unable to finance a lump-sum cash bonus. For the background of this decision, see Albuquerque Journal, Mar. 10, 1947, p. 2, col. 4; id., Feb. 25, 1947, p. 1, col. 3; id., Jan. 19,1947, p. 4, cols. 4-5; id., Jan. 8,1947, p. 1, cols. 2-3; id., Jan. 5, 1947, p. 10, col. 2.
The Court, however, makes the following remarkable statement:
“The New Mexico statute, by singling out previous residents for the tax exemption, rewards only those citizens for their ‘past contributions’ toward our nation’s military effort in Vietnam. Zobel teaches that such an objective is ‘not a legitimate state purpose.’ 457 U. S., at 63.” Ante, at 622-623.
Of course, what Zobel taught was that “past contributions” amounting to nothing more than residence in the State do not justify discrimination in favor of long-time residents; Zobel surely did not imply that past contributions to the Nation’s military effort would not justify a special reward, as the Court implicitly acknowledges when it recognizes as legitimate this Nation’s “ ‘longstanding policy of compensating veterans for their past contributions by providing them with numerous advantages.’ ” Ante, at 620 (quoting Regan v. Taxation With Representation of Wash., 461 U. S., at 551).
See ante, at 621.
Indeed, the New Mexico Legislature frequently extended the property tax exemption to veterans on a prospective basis. See 1933 N. M. Laws, ch. 44, p. 47 (approved Mar. 1, 1933, and applicable to all veterans of World War I resident as of Jan. 1,1934); 1923 N. M. Laws, ch. 130, p. 193 (approved Mar. 12, 1923, and applicable to all resident veterans). Other legislation was retroactive only by a few months. See 1947 N. M. Laws, ch. 79, p. 116 (approved Mar. 13, 1947, and applicable to all veterans of World War II resident as of Jan. 1, 1947). But see 1957 N. M. Laws, ch. 169, p. 256 (approved Mar. 28, 1957, and applicable to all Korean conflict veterans resident as of Jan. 1, 1955).
The 1983 law was captioned as an amendment “to enlarge the period during which a Vietnam veteran may qualify for an exemption from property taxes.” 1983 N. M. Laws, ch. 330, p. 2111.
Nor would I hold unconstitutional a provision in a State’s veterans’ assistance law which excluded veterans who had already received benefits in another State. New Mexico’s limitation of eligibility to Vietnam veterans taking up residence in the State prior to May 8, 1976, may in purpose and in practice have served to prevent “double-dipping” of just this kind.
The State Court of Appeals wrote:
“Hooper points out that the statute is undear as to whether the requirement at issue is a continuous residency requirement and that a veteran with only one day of New Mexico residency, immediately followed by an extended period of nonresidency prior to May 8,1976, might qualify for the exemption where Alvin D. Hooper does not.
“Such arguments are not, standing alone, sufficient to allow this court to consider the issues raised. The exemption was not denied on either ground raised in support of this position. Hooper does not have standing to challenge the statute on the due process grounds of vagueness raised, and we decline to issue an advisory opinion on the matter. Advance Loan Co. v. Kovach, 79 N. M. 609, 445 P. 2d 386 (1968); Asplund v. Alarid, 29 N. M. 129, 219 P. 786 (1923).” 101 N. M. 172, 177, 679 P. 2d 840, 845 (1984).
1 also discern no substance to appellants’ claim that the statutory classification violates the Due Process Clause of the Fourteenth Amendment. I further note that appellants’ jurisdictional statement raised no claim that New Mexico’s statute violates the Privileges and Immunities Clause of Article IV of the Constitution.