Sterling Holt v. Indiana Manufacturing Company

• Decision Date: 15 January 1900
• Docket Number: No. 30,30
• Parties: STERLING R. HOLT, Joel A. Baker, Thomas Taggart, George Wolf, William A. Bell, and Charles A. Stuckmeyer, Appts. , v. INDIANA MANUFACTURING COMPANY
• Court: U.S. Supreme Court

176 U.S. 68

20 S.Ct. 272

44 L.Ed. 374

STERLING R. HOLT, Joel A. Baker, Thomas Taggart, George Wolf, William A. Bell, and Charles A. Stuckmeyer, Appts.,

v INDIANA MANUFACTURING COMPANY.

No. 30.

Argued December 19, 20, 1899.

Decided January 15, 1900.

This suit was brought in the circuit court of the United States for the district of Indiana by the Indiana Manufacturing Company, a corporation organized and existing under the laws of the state of Indiana, against Sterling R. Holt and others, taxing officers of Marion county, Indiana, and of a township in said county, and some others, constituting the board of review of that county, all of whom were citizens of Indiana, to enjoin the collection of certain personal taxes for the years 1892, 1893, 1894, and 1895, assessed upon the capital stock and tangible property of the company. The bill alleged that the larger part of the assessment made by the taxing authorities was for the supposed value of certain rights under letters patent from the United States owned by the company, and which the company insisted were not subject to taxation by the state authorities; that the capital stock, aside from the tangible property, represented solely the supposed value of the letters patent; and that the taxes in respect of the tangible property had been paid by the company. Complainant charged that the assessment was illegal, unconstitutional, and void, and averred that the suit was instituted 'to redress the deprivation, under color of a law of the state of Indiana, of a right secured by the laws of the United States, and, further, that it is a suit arising under the patent laws of the United States.'

The circuit court entered a decree, in accordance with the prayer of the bill, perpetually enjoining the collection of the taxes claimed to be due in respect of the capital stock, in so far as the value thereof was derived from patent rights or letters patent owned by complainant. An appeal was taken to the circuit court of appeals for the seventh circuit, and dismissed by that court for want of jurisdiction. 46 U. S. App. 717, 80 Fed. Rep. 1, 25 C. C. A. 301.

The circuit court of appeals held that the suit was not one arising under the patent laws of the United States, and that, as the jurisdiction of the circuit court could rest only on the ground that the constitutional rights of complainant were infringed by the laws of the state of Indiana which were repugnant to and in contravention of the Constitution of the United States, an appeal would not lie to that court, and could only be taken directly to this court under § 5 of the judiciary act of March 3, 1891.

Messrs. William L. Taylor, Solicitor General John K. Richards, Merrill Moores, Cassius C. Hadley, William A. Ketcham, and Alfred R. Hovey for appellants.

Chester Bradford and Alonzo Greene Smith for appellee.

Mr. Chief Justice Fuller delivered the opinion of the court:

The decree of the circuit court was entered in March, 1896, and the appeal to this court was not taken until somewhat over one year and six months, though within two years, thereafter. In January, 1898, a motion to dismiss was made on the ground that § 1008 of the Revised Statutes, giving two years for the bringing of a writ of error or the taking of an appeal to review the judgments or decrees of the circuit or district courts, was repealed by the judiciary act of March 3, 1891. We did not concur in that view, and the motion was denied, though without an opinion. But in Allen v. Southern P. R. Co. 443 U. S. 479, 43 L. ed. 775, 19 Sup. Ct. Rep. 518, the reasons will be found for our conclusion that the limit of two years remained unchanged.

In this, as in all cases, if it appears that the circuit court had no jurisdiction, it is the duty of this court to so declare and enter judgment accordingly.

Complainant rested the jurisdiction on clauses 9 and 16 of § 629 of the Revised Statutes.

(1) Section 629 provides that 'the circuit courts shall have original jurisdiction as follows: . . . Ninth. Of all suits at law or in equity arising under the patent or copyright laws of the United States.'

The complaint that the assessment of these taxes was illegal because in effect levied on patents or patent rights did not involve the construction, or the validity, or the infringement of the patents referred to, or any other question under the patent laws. This was not, therefore, a suit 'arising under the patent laws,' and the circuit court had no jurisdiction on that ground. Dale Tile Mfg. Co. v. Hyatt, 125 U. S. 46, 31 L. ed. 683, 8 Sup. Ct. Rep. 756; Walter A. Wood Mowing & Reaping Mach. Co. v. Skinner, 139 U. S. 293, 35 L. ed. 193, 11 Sup. Ct. Rep. 528; Wade v. Lawder, 165 U. S. 624, 41 L. ed. 851, 17 Sup. Ct. Rep. 425.

(2) The 16th clause of § 620 reads thus: 'Of all suits suthorized by law to be brought by any person to redress the deprivation, under color of any law, statute, ordinance, regulation, custom, or usage of any state, of any right, privilege, or immunity secured by the Constitution of the United States, or of any right secured by any law providing for equal rights of citizens of the United States, or of all persons within the jurisdiction of the United States.'

Similar jurisdiction is conferred upon district courts by the 12th clause of § 563 of the Revised Statutes.

Section 1979 of the...