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U.S. Supreme Court

Worcester County Trust Co. v. Riley, 302 U.S. 292 (1937)

Worcester County Trust Co. v. Riley

No. 34

Argued November 15, 16, 1937

Decided December 6, 1937

302 U.S. 292


1. State taxing officials seeking through judicial proceedings to assess a succession tax on intangible property in pursuance of laws of their State, which impose the tax only if the deceased was domiciled therein at death, cannot constitutionally be interpleaded in a federal court with tax officials of another State likewise claiming the domicile and the right to tax, in order that the federal court may determine which State is in fact domiciliary and enjoin taxation in the other State, for the purpose of avoiding double taxation. P. 302 U. S. 296.

Such a suit is in effect against the State, forbidden by the Eleventh Amendment.

A bill of interpleader, brought by an executor against tax officials of California and of Massachusetts, alleged that the California officials had determined and were asserting that the decedent at death, was domiciled in that State, and were threatening to assess and collect under California laws, applicable in case of local domicile, a death tax upon all his intangibles, which would be in excess of any tax that would be due if the domicile was Massachusetts, and that the Massachusetts official, in behalf of his State, was asserting that the domicile was in Massachusetts and the estate taxable there upon all the intangibles; that it was impossible in law and in fact for decedent to have been domiciled in both States at the time of his death, or for his estate to be subject to death taxes in both States as asserted, and that attempted collection was a threatened deprivation of property without due process of law and denial of equal protection of the laws. The bill prayed that the court order the respondent officials of the two States to interplead their respective claims for the tax; that the court determine the domicile of decedent, the amount of the tax, and the person or persons to whom it was payable, and that respondents be enjoined from any other proceedings to collect it. Held that, on objection of the California respondents, the suit was properly dismissed as, in substance, a suit against the State.

Page 302 U. S. 293

2. Under California statutes, inheritance taxes are assessed by judicial proceedings resulting, after full opportunity for presentation of evidence and a hearing, in a judgment which is reviewable on appeal by the state courts, and by this Court if it involves any denial of federal right. P. 302 U. S. 298.

3. Conflicting decisions of the same issue of fact do not necessarily imply judicial error. P. 302 U. S. 299.

4. Neither the Fourteenth Amendment nor the full faith and credit clause requires uniformity in the decisions of the courts of different States as to the place of domicile where the exertion of state power is dependent upon domicile. P. 302 U. S. 299.

5. City Bank Former Trust Co. v. Schnader, 291 U. S. 24, distinguished. P. 302 U. S. 300.

89 F.2d 59 affirmed.

Certiorari, 301 U.S. 678, to review the reversal of a decree granting a temporary injunction in an interpleader suit, 14 F.Supp. 754.

Page 302 U. S. 294

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