Santa Clara County v. Southern Pacific Railroad Company

jgoldman — Tue, 26 Jan 1886 13:00:00 +0000

Location

Southern Pacific Railroad Co. headquarters San Francisco, CA

United States

37° 46' 29.748" N, 122° 25' 9.8976" W

See map: Google Maps

Case Basics

Plaintiff in error

Santa Clara County

Petitioner Type

Plaintiff In Error

Defendant in error

Southern Pacific Railroad Company et al.

Respondent Type

Defendant In Error

Consolidation

People of the State of California v. Central Pacific Railroad Company

People of the State of California v. Southern Pacific Railroad Company

Opinion

118 U.S. 394 (1886)

Argued

January 26-29, 1886

Decided

Monday, May 10, 1886

Advocates

E. C. Marshall (Attorney General of California, argued the cause for the plaintiffs in error)

S. W. Sanderson (argued the cause for the defendants in error)

George F. Edmunds (argued the cause for the defendants in error)

William M. Evarts (argued the cause for the defendants in error)

Facts of the Case

The state of California taxed fences owned by Southern Pacific Railway Company, but Southern Pacific asserted that the state constitution only allowed taxes on "the franchise, roadway roadbed, rails, and rolling stock." Southern Pacific also claimed that state tax board did not properly subtract its outstanding mortgages from the value of its property. Southern Pacific refused to pay taxes on its fences and the difference account for by subtracting outstanding mortgages. Santa Clara County brought action against it in a state court. The county argued that since it could tax the land which situated the fences, it could also tax the additional value of the land added by the fences. Southern Pacific had the action moved to a federal district court, which ruled that the state did not have jurisdiction to tax fences. The county appealed to the Supreme Court.

Question

Did the California constitution allow the state to increase property taxes against railroad companies when the companies added additional value to the property by building fences? Did the state tax board wrongfully tax property without deducting for the outstanding mortgages against the property owners?

Conclusion

No and Yes. Justice John Marshall Harlan delivered the opinion for a unanimous court. The state tax board tried to levy a single sum against the railway company which both wrongfully included the value of the fences and excluded a deduction for the outstanding mortgages. The state tax board increased taxes on the property based on a arbitrary measure of the value added by the fences. The state constitution required the state and its counties to separately assess the "land, and improvements thereon" before increasing taxes. A state statute specified fences as a form of land improvement. The decision famously implied that equal protection laws provided by the Fourteenth Amendment applied to corporations, but the opinion did not explicitly state this.

United States v. Kagama

jgoldman — Tue, 02 Mar 1886 13:00:00 +0000

Location

Hoopa Valley Indian Reservation Hoopa, CA

United States

41° 7' 26.4" N, 123° 41' 0.96" W

See map: Google Maps

Case Basics

Plaintiff in error

United States

Petitioner Type

Plaintiff In Error

Defendant in error

Kagama

Respondent Type

Defendant In Error

Heard By

Waite Court (1882-1887)

Decided By

Waite Court (1882-1887)

Opinion

118 U.S. 375 (1886)

Argued

Tuesday, March 2, 1886

Decided

Monday, May 10, 1886

Advocates

John Goode (Solicitor General, Department of Justice, argued the cause for the United States)

Joseph D. Redding (argued the cause for the defendants in error)

Facts of the Case

In response to the Court's ruling in Ex Parte Crowe Dog (1883), Congress passed the Major Crimes Act as part of the Indian Appropriations Act of 1885, which granted the federal courts jurisdiction over certain major crimes committed by one Native American against another. In June 1885, Kagama, a Native American, was tried for the murder of Iyouse, another Native American, on the Hoopa Valley reservation in California. At trial, Kagama challenged the court's jurisdiction over the matter, arguing that the relevant section of the Indian Appropriations Act was unconstitutional. On appeal, Kagama received a division of opinion from the Circuit Court of the United States for the District of California.

Question

Does any part of the Constitution grant Congress the power over the jurisdiction of crimes committed by one Native American against another?

Conclusion

Yes. In a unanimous opinion authored by Justice Samuel F. Miller, the Court acknowledged, "The Constitution of the United States is almost silent in regard to the relations of the government which was established by it to the numerous tribes of Indians within its borders." Nonetheless, the Court reasoned that, because the tribal governments "owe all their powers to the statutes of the United States conferring on them the powers which they exercise, and which are liable to be withdrawn, modified, or repealed at any time by Congress," the legislature could therefore control jurisdiction of crimes committed within reservations. Describing Native Americans as "wards of the nation," the Court concluded, "From their very weakness and helplessness, so largely due to the course of dealing of the Federal Government with them and the treaties in which it has been promised, there arises the duty of protection, and with it the power."

Cases - 1885 term

Santa Clara County v. Southern Pacific Railroad Company

Location

United States v. Kagama

Location