Conroy v. Aniskoff

Citation507 U.S. 511,113 S.Ct. 1562,123 L.Ed.2d 229
Decision Date31 March 1993
Docket NumberNo. 91-1353,91-1353
PartiesThomas F. CONROY, Petitioner v. Walter ANISKOFF, Jr., et al
CourtUnited States Supreme Court
Syllabus *

When petitioner Conroy, an officer in the United States Army, failed to pay local real estate taxes on property he owned in Danforth, Maine, the town acquired the property and sold it. In his suit against the town and the property's purchasers, Conroy claimed that § 525 of the Soldiers' and Sailors' Civil Relief Act of 1940—which provides that the "period of military service" shall not "be included in computing any period . . . provided by any law for the redemption of real property sold or forfeited to enforce any obligation, tax, or assessment"—tolled the redemption period while he was in military service, and federal law therefore prevented the town from acquiring good title to the property. The Maine District Court rejected his claim, holding that the redemption period could not be tolled unless the taxpayer could show that military service resulted in hardship excusing timely legal action, and that it would be absurd and illogical to toll limitations periods for career service personnel who had not been handicapped by their military status. The State Supreme Judicial Court affirmed.

Held: A member of the Armed Services need not show that his military service prejudiced his ability to redeem title to property before he can qualify for the statutory suspension of time. The statutory command in § 525 is unambiguous, unequivocal, and unlimited. There is no support for respondents' argument that when § 525 is read in the context of the entire statute, it implicitly conditions its protection on a demonstration of hardship or prejudice resulting from military service. The statute's complete legislative history confirms a congressional intent to protect all military personnel on active duty, not just those whose lives have been temporarily disrupted by the service. In addition, the statute's comprehensive character indicates that Congress included a prejudice requirement whenever it considered it appropriate to do so, and that its omission of any such requirement in § 525 was deliberate. Finally, both the history of this carefully reticulated statute, and this Court's history of interpreting it, refute any argument that a literal construction of § 525 is so absurd or illogical that Congress could not have intended it. Pp. ____.

599 A.2d 426 (Me.1991), reversed.

STEVENS, J., delivered the opinion of the Court, in which REHNQUIST, C.J., and WHITE, BLACKMUN, O'CONNOR, KENNEDY, and SOUTER, JJ., joined, and in all but n. 12 of which THOMAS, J., joined. SCALIA, J., filed an opinion concurring in the judgment.

Robert H. Klonoff, Washington, D.C., for petitioner.

John F. Manning for U.S., as amicus curiae by special leave of the Court.

Kevin M. Cuddy, Bangor, ME, for respondents.

Justice STEVENS delivered the opinion of the Court.*

The Soldiers' and Sailors' Civil Relief Act of 1940, 54 Stat. 1178, as amended, 50 U.S.C.App. § 501 et seq. (Act), suspends various civil liabilities of persons in military service. At issue in this case is the provision in § 525 that the "period of military service shall not be included in computing any period . . . provided by any law for the redemption of real property sold or forfeited to enforce any obligation, tax, or assessment." 1 The question

I

Petitioner is an officer in the United States Army. He was on active duty continuously from 1966 until the time of trial. In 1973 he purchased a parcel of vacant land in the town of Danforth, Maine. He paid taxes on the property for 10 years, but failed to pay the 1984, 1985, and 1986 local real estate taxes.2 In 1986, following the Maine statutory procedures that authorize it to acquire tax-delinquent real estate, the town sold the property.3

In 1987 petitioner brought suit in the Maine District Court against the town and the two purchasers. He claimed that § 525 of the Act tolled the redemption period while he was in military service, and federal law therefore prevented the town from acquiring good title to the property even though the State's statutory procedures had been followed. The trial court rejected the claim. In an unreported opinion, it noted that some courts had construed § 525 literally, but it elected to follow a line of decisions that refused to toll the redemption period unless the taxpayer could show that "military service resulted in hardship excusing timely legal action." 4 It agreed with those courts that it would be "absurd and illogical" to toll limitations periods for career service personnel who had not been "handicapped by their military status." 5 The Supreme Judicial Court of Maine affirmed by an equally divided court.6 We granted certiorari to resolve the conflict in the interpretation of § 525. 505 U.S. ----, 112 S.Ct. 2989, 120 L.Ed.2d 867 (1992).

II

The statutory command in § 525 is unambiguous, unequivocal, and unlimited. It states that the period of military service "shall not be included" in the computation of "any period now or hereafter provided by any law for the redemption of real property. . . ." Respondents do not dispute the plain meaning of this texte. Rather, they argue that when § 525 is read in the context of the entire statute, it implicitly conditions its protection on a demonstration of hardship or prejudice resulting from military service. They make three points in support of this argument: that the history of the Act reveals an intent to provide protection only to those whose lives have been temporarily disrupted by military service; that other provisions of the Act are expressly conditioned on a showing of prejudice; and that a literal interpretation produces illogical and absurd results. Neither separately nor in combination do these points justify a departure from the unambiguous statutory text.

Respondents correctly describe the immediate cause for the statute's enactment in 1940, the year before our entry into World War II. Congress stated its purpose to "expedite the national defense under the emergent conditions which are threatening the peace and security of the United States. . . ." 50 U.S.C.App. § 510. That purpose undoubtedly contemplated the special hardship that military duty imposed on those suddenly drafted into service by the national emergency.7 Neither that emergency, nor a particular legislative interest in easing sudden transfers from civilian to military status, however, justifies the conclusion that Congress did not intend all members of the Armed Forces, including career personnel, to receive the Act's protections. Indeed, because Congress extended the life of the Act indefinitely in 1948,8 well after the end of World War II, the complete legislative history confirms a congressional intent to protect all military personnel on active duty, just as the statutory language provides.

Respondents also correctly remind us to "follow the cardinal rule that a statute is to be read as a whole, see Massachusetts v. Morash, 490 U.S. 107, 115, 109 S.Ct. 1668, 1673, 104 L.Ed.2d 98 (1989), since the meaning of statutory language, plain or not, depends on context." King v. St. Vincent's Hospital, 502 U.S. ----, ----, 112 S.Ct. 570, 574, 116 L.Ed.2d 578 (1991). But as in King, the context of this statute actually supports the conclusion that Congress meant what § 525 says. Several provisions of the statute condition the protection they offer on a showing that military service adversely affected the ability to assert or protect a legal right. To choose one of many examples, § 532(2) authorizes a stay of enforcement of secured obligations unless "the ability of the defendant to comply with the terms of the obligation is not materially affected by reason of his military service." 9 The comprehensive character of the entire statute indicates that Congress included a prejudice requirement whenever it considered it appropriate to do so, and that its omission of any such requirement in § 525 was deliberate.

Finally, both the history of this carefully reticulated statute, and our history of interpreting it, refute any argument that a literal construction of § 525 is so absurd or illogical that Congress could not have intended it. In many respects the 1940 Act was a re-enactment of World War I legislation that had, in turn, been modeled after legislation that several States adopted during the Civil War. See Boone v. Lightner, 319 U.S. 561, 565-569, 63 S.Ct. 1223, 1226-1228, 87 L.Ed. 1587 (1943). The Court had emphasized the comprehensive character and carefully segregated arrangement of the various provisions of the World War I statute in Ebert v. Poston, 266 U.S. 548, 554, 45 S.Ct. 188, 190, 69 L.Ed. 435 (1925), and it had considered the consequences of requiring a showing of prejudice when it construed the World War II statute in Boone, supra. Since we presume that Congress was familiar with those cases,10 we also assume that Congress considered the decision in Ebert to interpret and apply each provision of the Act separately when it temporarily re-established the law as a whole in 1940, and then considered Boone's analysis of a prejudice requirement when it permanently extended the Act in 1948.

Legislative history confirms that assumption. Since the enactment of the 1918 Act, Congress has expressed its understanding that absolute exemptions might save time or money for service members only at the cost of injuring their own credit, their family's credit, and the domestic economy; 11 it presumably required a showing of prejudice only when it seemed necessary to confer on the service member a genuine benefit. By distinguishing sharply between the two types of protections, Congress unquestionably contemplated the ways that either type of protection would affect both military debtors and their civilian creditors.

The long and consistent history and the structure of this legislation therefore leads us to...

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