Chief Justice ROBERTS delivered the opinion of the Court.
The Railroad Revitalization and Regulatory Reform Act of 1976 prohibits States from discriminating against railroads by taxing railroad property more heavily than other commercial 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. Burlington Northern R. Co. v. Oklahoma Tax Comm'n,
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