[22-166] Tyler v. Hennepin County, Minnesota

Tyler v. Hennepin County, Minnesota

Wikipedia · Justia (with opinion) · Docket · oyez.org

Argued on Apr 26, 2023.
Decided on May 25, 2023.

Petitioner: Geraldine Tyler.
Respondent: Hennepin County, Minnesota, et al..

Advocates:

• Christina M. Martin (for the Petitioner)
• Erica L. Ross (for the United States, as amicus curiae, supporting neither party)
• Neal Kumar Katyal (for the Respondents)

Facts of the case (from oyez.org)

Geraldine Tyler owned a condominium in Minneapolis. She stopped paying her property taxes and accrued a tax debt of $15,000. To satisfy the debt, Hennepin County foreclosed on Tyler’s property and sold it for $40,000, retaining the net proceeds from the sale.

Tyler sued the County, arguing that its actions violated her constitutional rights. The district court dismissed Tyler’s case for failure to state a claim, and the U.S. Court of Appeals for the Eighth Circuit affirmed.

Question

1. Does taking and selling a home to satisfy a debt to the government, and keeping the surplus value as a windfall, violate the Fifth Amendment’s Takings Clause?

2. Is the forfeiture of property worth far more than needed to satisfy a debt a fine within the meaning of the Eighth Amendment?

Conclusion

Taking and selling a home to satisfy a debt to the government, and keeping the surplus value as a windfall, violates the Fifth Amendment’s Takings Clause. Chief Justice John Roberts authored the unanimous opinion of the Court holding that Tyler plausibly alleged that Hennepin County’s actions violated the Takings Clause and thus that her claim can go forward.

The Takings Clause of the Fifth Amendment, applicable to the States through the Fourteenth Amendment, prohibits the government from taking private property without “just compensation.” This does not prevent the government from collecting taxes, or from taking action to enforce the collection of taxes. However, the government may not, as Minnesota purported to do by statute in 1935, extinguish a property owner’s interest in property when she falls behind on her property taxes. English law, from which the U.S. Constitution derives much meaning, has long proscribed the taking of more from a taxpayer than she owes. Moreover, Supreme Court precedents and Minnesota law itself, in other contexts, recognize the principle that a taxpayer is entitled to the surplus in excess of the debt owed.

Justice Neil Gorsuch authored a concurring opinion, in which Justice Ketanji Brown Jackson joined, addressing the second question presented, which the majority declined to address. In Justice Gorsuch’s view, Hennepin County’s actions likely also violate the Eighth Amendment’s Excessive Fines Clause.