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Keywords

discrimination

plaintiffjurisdictionstatutediscriminationgood faith

Related Cases

Sunday Lake Iron Co. v. Wakefield Tp., 247 U.S. 350, 38 S.Ct. 495, 62 L.Ed. 1154

Facts

The Sunday Lake Iron Company was assessed for its property in 1911 at full value of $1,071,000 by the state board of tax assessors, while other lands in the county were generally assessed at not exceeding one-third of their actual worth. An inexperienced local assessor initially adopted a valuation of $65,000, which was approved by the county board of review. The state board later raised the assessment based on a report by experts, but did not conduct a general survey of other properties despite the company's offer to present evidence of their lower valuations.

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.

Issue

Did the state board of tax assessors' actions constitute a violation of the Sunday Lake Iron Company's right to equal protection under the Fourteenth Amendment?

Rule

The equal protection clause of the Fourteenth Amendment secures individuals against intentional and arbitrary discrimination by state officials, and systematic undervaluation of property in the same class contravenes the constitutional right of one taxed on full value.

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.

Analysis

The court analyzed whether the state board's assessment practices were intentionally discriminatory. It found that while the Sunday Lake Iron Company's property was assessed relatively higher than others, there was insufficient evidence to prove that the state board acted with a purpose to discriminate. The court noted that the board's actions could be seen as an honest effort to establish valuations under challenging circumstances, and that the company did not provide adequate evidence to justify a general revaluation of other properties at the time.

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.

Conclusion

The court affirmed the lower court's judgment, concluding that the Sunday Lake Iron Company was not denied equal protection under the law.

The judgment of the court below must be Affirmed.

Who won?

The Township of Wakefield prevailed in the case because the court found no intentional discrimination in the assessment process by the state board.

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