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U.S. Supreme Court

Winona and St. Peter Land Co. v. Minnesota, 159 U.S. 526 (1895)

Winona and St. Peter Land Company v. Minnesota

No. 31

Argued October 16, 1895

Decided November 11, 1895

159 U.S. 526


The provisions in the statutes of Minnesota exempting from taxation the lands granted by the state to the Winona and St. Peter Railroad Company to aid in the construction of its railroad until the land should be sold and conveyed by the company ceased to be operative when the full equitable title was transferred by the company, and the railroad company could not thereafter, by neglecting to convey the legal title, indefinitely postpone the exemption. State v. Winona and St. Peter Railroad Co., 21 Minn. 472, followed.

Statutes exempting property from taxation are to be strictly construed.

Chapter 5 of the Laws of Minnesota of 1881, providing generally for the assessment and taxation of any real or personal property which had been omitted from the tax roll of any preceding year or years, does not, when applied to the land granted by that state to the Winona and St. Peter Railroad Company, deprive the owners of that land of their property without due process of law in violation of the provisions of the Fourteenth Amendment to the Constitution of the United States.

A legislature can provide for collecting back taxes on real property without making a like provision respecting back taxes on personal property.

On March 3, 1857, Congress passed an act, 11 Stat. 195, c. 99, granting lands to the Territory (now State) of Minnesota to aid in the building of railroads. On May 22, 1857, the

Page 159 U. S. 527

territorial legislature granted a portion of these lands, including those in controversy, to the Transit Railroad Company. Laws of Minnesota, 1857, special session, p. 17. The fourth section of subchapter 2 of this act provided that "the lands so granted shall be and are exempted from all taxation until the same shall have been sold and conveyed by said company." The Transit Company failed to comply with the conditions of this act, and thereafter, by an act passed March 10, 1862, all its rights, benefits, property, and franchises, including the exemption of the lands from taxation, were transferred to the Winona and St. Peter Railroad Company. Laws of Minnesota, 1862, p. 243. The latter company accepted the transfer and grant and proceeded to build the railroad, and, as built, the lands were from time to time certified to the state, and by the state deeded to the company, some of the lands being thus conveyed in 1869 and other in 1870 and 1871.

On October 31, 1867, the railroad company entered into a contract with D. N. Barney and others. This contract recited the adjustment and settlement of an indebtedness of the company to Barney and his associates for money theretofore advanced, and provided for payment thereof in bonds and lands. No particular description was made in this contract of the lands to be thus conveyed, but only a general reference to the lands as those included in this congressional and state grant. The plaintiff in error, having succeeded to the rights of Barney and his associates, sought to obtain title to the lands, but the railroad company refused to convey, whereupon, in 1879, suit was instituted, which terminated March 7, 1887, in a final decree of the circuit court of the United States directing a conveyance.

In 1881 (Laws 1881, c. 5, p. 24) the Legislature of Minnesota passed an act providing generally for the assessment and taxation of any real or personal property which had been omitted from the tax roll of any preceding year or years. Under this statute, in 1886, the officers of Redwood County proceeded to assess and tax these lands for the taxes of past years. In the proceedings thus instituted, the plaintiff in error appeared and defended on the ground that the lands were,

Page 159 U. S. 528

by virtue of the fourth section of subchapter 2 of the Act of May 22, 1857, exempt from taxation until after the decree of March 7, 1887, and also on the further ground that the act of 1881 was unconstitutional in failing to provide proper notice to the owners of the property sought to be assessed and taxed. The proceedings terminated adversely to the plaintiff in error, and it immediately sought a review thereof in the supreme court of the state. That court directed judgment to be entered against the land for the taxes for the six years immediately preceding the assessment, holding that all claims for taxes for prior years were barred by the statute of limitations. Redwood County v. Winona & St. Peter Land Co., 40 Minn. 512. To reverse this judgment, plaintiff in error sued out this writ of error.

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