Sunday Lake Iron Co. v. Township of Wakefield
Sunday Lake Iron Company v. Township of Wakefield
Syllabus
Summary
Syllabus and headnotes are prepared by the reporter or publisher, not the court, and are not part of the opinion.
Opinion
Me. Justice McReynolds delivered the opinion of the court.
This is a writ of error to a state court and the only matter for our consideration is the claim that contrary to the Fourteenth Amendment plaintiff in error was denied equal protection of the laws by the State Board of Tax Assessors which assessed its property for 1911 at full value, whereas other lands throughout the county were generally assessed at not exceeding one-third of their actual worth. Proceeding in entire good faith, an inexperienced local assessor adopted the .valuation which his predecessor had placed upon the company’s property —$65,000.00; the County Board of Review approved his action. Reviewing this in the light of a subsequent detailed report by experts appointed under a special act of the legislature passed in April, 1911, to appraise all mining properties, the State Board raised the assessment to $1,071,000.00; but, becausé of alleged lack of time and inadequate information, it declined to order a new and general survey of values or generally to increase other assessments, notwithstanding plaintiff in error represented and offered to present evidence showing that they amounted to no more than one-third of true market values.
The purpose of the equal protection clause of the Fourteenth Amendment is to secure every person within the State’s jurisdiction against intentional and arbitrary discrimination, whether occasioned by express terms of a statute or by its improper execution through duly constituted agents. And it must be regarded as settled that intentional systematic undervaluation by state officials of *353 other taxable property in the same class contravenes the constitutional right of one taxed upon the full value of his property.
Raymond v. Chicago Union Traction Co., 207 U. S. 20, 35, 37 . It is also clear that mere errors of judgment by officials will not support a claim of discrimination. There must be something more — something which in effect amounts to an intentional violation of the essential principle of practical uniformity. The good faith of such officers and the validity of their actions are presumed; when assailed, the burden of proof is upon the complaining party.
Head Money Cases, 112 U. S. 580, 595 ;
Pittsburgh &c. Ry. Co.
v. Backus, 154 U. S. 421, 435 ;
Maish v. Arizona, 164 U. S. 599, 611 ;
Adams Express Co.
v. Ohio, 165 U. S. 194, 229 ;
New York State v. Barker, 179 U. S. 279, 284, 285 ;
Coulter v. Louisville & Nashville R. R. Co., 196 U. S. 599, 608 ;
Chicago, Burlington & Quincy Ry. Co.
v. Babcock, 204 U. S. 585, 597 .
The record discloses facts which render it more than probable that plaintiff in error’s mines were assessed for the year 1911 (but not before or afterwards) relatively higher than other lands within the county although the statute enjoined the same rule for all. But we are unable to conclude that' the evidence suffices clearly to establish that the State Board entertained or is chargeable with any purpose or design to discriminate. Its action is not incompatible with an honest effort in new and difficult circumstances to adopt valuations not relatively unjust or unequal. When plaintiff in error first challenged the values placed upon the' property of others no adequate time remained for detailed consideration nor was there sufficient evidence before the Board to justify immediate and general revaluations. The very next year a diligent and, so far as appears, successful effort was made to rectify any inequality. The judgment of the court below must be Affirmed.
How later courts describe this case
Explanatory parentheticals written by citing courts — 14 in all; the most informative distinct ones are shown.
-
(holding that good-faith imposition of temporarily unequal tax burden did not violate the Equal Protection Clause of the United States Constitution)
-
(finding no “purpose or design to discriminate” and that “[the town’s] action is not incompatible with an honest effort in new and difficult circumstances to adopt valuations not relatively unjust or unequal”)
-
(assessment of one taxpayers' property at full value while generally assessing other taxpayers' properties at fraction of value)
-
(" The purpose of the equal protection clause of the 14th Amendment is to secure every person within the state's jurisdiction against intentional and arbitrary discrimination....")
-
(quoted in Village ofWillowbrook v. Olech, 528 U.S. 562, 564, 120 S.Ct. 1073, 145 L.Ed.2d 1060 (2000))
-
(“[M]ere errors of judgment by officials will not support a claim of discrimination. There must be something more— something which in effect amounts to an intentional violation of the essential principle of practical uniformity.”)
-
(property tax upheld under equal protection challenge even though petitioner's property assessed at full value while other property assessed at one-third value because it was not clearly established that the town board purposely discriminated)
-
(although challenged assessment was probably higher than others under the same statute, no violation of equal protection occurred in absence of “systematic undervaluation ... of other taxable property” or “any purpose or design [of the taxing authority] to discriminate”)
Cited by 358 cases
View all citing references →- U.S. Supreme Court20
- U.S. Courts of Appeals32
- Federal District Courts65
- Bankruptcy Courts1
- Federal Specialty Courts6
- Military Courts1
- State Highest Courts141
- State Appellate Courts68
- State Trial Courts8
- State Specialty Courts8
- State Attorney General Opinions3
- Territorial Courts5
Relies on it most ⓘ
Citing references are not a citator: they show that a later opinion cites this case, not whether it followed, distinguished, or overruled it. Check negative history before relying on this case.