Sunday Lake Iron Co v. Wakefield Tp
Citation | 62 L.Ed. 1154,38 S.Ct. 495,247 U.S. 350 |
Decision Date | 03 June 1918 |
Docket Number | No. 38,38 |
Parties | SUNDAY LAKE IRON CO. v. WAKEFIELD TP |
Court | United States Supreme Court |
Messrs. Horace Andrews, of Cleveland, Ohio, and William P. Belden, of Ishpeming, Mich., for plaintiff in error.
[Argument of Counsel pages 350-352 intentionally omitted] Mr. James A. O'Neill, of Ironwood, Mich., for defendant in error.
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—sixty-five thousand dollars; 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; but, because 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 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, 28 Sup. Ct. 7, 52 L. Ed. 78, 12 Ann. Cas. 757. 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...
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...class contravenes the constitutional right of one taxed upon the full value of his property." (Sunday Lake Iron Co. v. Wakefield (1918) 247 U.S. 350, 352-353, 38 S.Ct. 495, 495, 62 L.Ed. 1154; see also Raymond v. Chicago Traction Co. (1907) 207 U.S. 20, 36-37, 28 S.Ct. 7, 52 L.Ed. 78; Sioux......
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