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Keywords

injunctiontrialtax lawrespondent

contracttrialtax lawrespondentlevy

Related Cases

Culliton v. Chase, 174 Wash. 363, 25 P.2d 81

Facts

Respondents alleged that the state income tax law was unconstitutional and filed two actions against the members of the state tax commission to obtain a permanent injunction against the enforcement of the law. The trial court determined that the income tax law violated the uniformity requirement of the Fourteenth Amendment, leading to the decree that permanently restrained the enforcement of the act. The law imposed a graduated tax rate based on income, which the court found inconsistent with the constitutional definition of property.

The trial court was of the view that the challenged act offended against the uniformity requirement of the Fourteenth Amendment to the State Constitution and was therefore void.

Issue

The main legal issue was whether the income tax law constituted a property tax and, if so, whether it violated the uniformity requirement of the Fourteenth Amendment to the State Constitution.

Rule

The court applied the principle that all taxes must be uniform upon the same class of property, as defined by the Fourteenth Amendment to the State Constitution, which states that 'the word ‘property’ as used herein shall mean and include everything, whether tangible or intangible, subject to ownership.'

The Fourteenth Amendment to the State Constitution reads: ‘The power of taxation shall never be suspended, surrendered or contracted away. All taxes shall be uniform upon the same class of property within the territorial limits of the authority levying the tax and shall be levied and collected for public purposes only.'

Analysis

The court analyzed the income tax law in light of the constitutional definition of property, concluding that income is indeed property for taxation purposes. The graduated rates imposed by the income tax law were found to lack uniformity, as they taxed individuals at different rates based on their income levels, which violated the constitutional requirement that all taxes be uniform upon the same class of property.

The fact that the income tax law was passed as an initiative measure is of no controlling importance, nor can it be likened to an amendment to the Constitution. The Constitution provides the means, methods, and processes for its own amendment.

Conclusion

The court affirmed the trial court's decree, holding that the income tax law was unconstitutional due to its violation of the uniformity requirement of the Fourteenth Amendment.

For the reasons herein stated, the decree of the trial court is affirmed.

Who won?

The respondents prevailed in the case as the court upheld the trial court's ruling that the income tax law was unconstitutional.

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