SUNDAY LAKE IRON COMPANY
v.
TOWNSHIP OF WAKEFIELD

U.S. | 1918-06-03
No. 38
247 U.S. 350 Supreme Court of the United States (1918) Caution
Also reported at: 62 L. Ed. 1154 · 38 S. Ct. 495 · SCDB 1917-147 · 1918 U.S. LEXIS 1917
Cited by 158 cases

AI-generated. These summaries, headnotes, and key points are machine-generated and may contain errors or omissions. Always verify against the full opinion text below. Not legal advice.

Synopsis

Sunday Lake Iron Company challenged a Michigan property tax assessment as violating the Fourteenth Amendment's Equal Protection Clause, claiming its mining property was assessed at full value while other lands in the county were assessed at roughly one-third of their actual worth. The Supreme Court affirmed the state court's judgment, holding that while intentional systematic undervaluation of other property in the same class would violate equal protection, the complaining party bears the burden of proof, and mere errors of judgment or honest administrative efforts do not constitute unlawful discrimination.

© FLexlaw, Inc. — AI-generated enrichments are proprietary. All rights reserved.

Opinion of the Court
Me. Justice McReynolds

Mr. Justice McReynolds delivered the opinion of the court.

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 —$65,000.00; 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 $1,071,000.00; but, becausé 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. 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 of such officers and the validity of their actions are presumed; when assailed, the burden of proof is upon the complaining party. Head Money Cases, 112 U. S. 580, 595; Pittsburgh &c. Ry. Co. v. Backus, 154 U. S. 421, 435; Maish v. Arizona, 164 U. S. 599, 611; Adams Express Co. v. Ohio, 165 U. S. 194, 229; New York State v. Barker, 179 U. S. 279, 284, 285; Coulter v. Louisville & Nashville R. R. Co., 196 U. S. 599, 608; Chicago, Burlington & Quincy Ry. Co. v. Babcock, 204 U. S. 585, 597.

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. Its action is not incompatible with an honest effort in new and difficult circumstances to adopt valuations not relatively unjust or unequal. When plaintiff in error first challenged the values placed upon the' property of others no adequate time remained for detailed consideration nor was there sufficient evidence before the Board to justify immediate and general revaluations. The very next year a diligent and, so far as appears, successful effort was made to rectify any inequality. The judgment of the court below must be

Affirmed.

Cases With Similar Vibessemantic neighbors from the corpus

Citator

Cited By (53 total)

  • Camp Phosphate Co. v. Allen, 77 Fla. 341 (Fla. 1919)
    …be regarded as settled that intentional, systematic undervaluation by tax officials of other taxable property in the same class contravenes the constitutional right of one whose property is overvalued. Sunday Lake Iron Co. v. Township of Wakefield, 247 U. S. 350, 62 L. Ed. 1154, — Sup. Ct. Rep. —; Raymond v. Chicago Union Traction Co., 207 U. S. 20, text 35, 37, 52 L. Ed. 78, text 87, 28 Sup. Ct. Rep. 7, 12 Ann. Cas. 757. On the other hand, it is held that mere errors of judgment by officials will not suppo…
  • Colonial Inv. Co. v. Nolan, 100 Fla. 1349 (Fla. 1930)
    …ights of one whose property is overvalued.” Camp Phosphate Co. v. Allen, 77 Fla. 341; 81 So. R. 503; Sioux City Bridge Co. v. Dalota County, 260 U. S. 441, 43 C. Ct. 190, 67 L. Ed. 340, 28 A. L. R. 979; Sunday Lake Iron Co. v. Township of Wakefield, 247 U. S. 350, 38 Sup. Ct. R. 495, 62 L. Ed. 1154; City of Tampa v. Palmer, 89 Fla. 514, 105 So. R. 115. “Uniformity and equality of rate and just valuation are required.” Louisville & N. R. Co. v. Amos, 123 So. R. 745, 747. It was argued below that the penalty…
    1 / 2
  • Louisville & Nashville R.R. Co. v. Amos, 98 Fla. 350 (Fla. 1929)
    …ontravenes the constitutional rights of one whose property is over valued. Camp Phosphate Co. v. Allen, 77 Fla. 341, 81 So. R. 503; Sioux City Bridge Co. v. Dakota County, 260 U. S. 441, 67 Law Ed. 340; Sunday Lake Iron Co. v. Township of Wakefield, 247 U. S. 350, 62 Law Ed. 1154; City of Tampa v. Palmer, 89 Fla. 514; 105 So. R. 115. Uniformity and equality of rate and just valuation are required. Unlawful discrimination is forbidden. Where illegal discrimination is practiced, it is immaterial whether it is…

Previewing 3 of 53 citing cases — full citator treatment, depth of discussion, and citing context are member features.

Join FLexlaw to unlock all legal intelligence

Authorities Cited

Full citator, related cases, and AI research tools

Open in FLexlaw