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U.S. Supreme Court

Coulter v. Louisville & Nashville R. Co., 196 U.S. 599 (1905)

Coulter v. Louisville and Nashville Railroad Company

No. 244

Argued November 29-30, 1904

Decided February 20, 1905

196 U.S. 599


A railroad company in Kentucky claimed as its only ground of federal jurisdiction in an action in the circuit court of the United States against members of the state board of valuation and assessment that, under the tax laws of the state, it was deprived of equal protection of the laws contrary to the Fourteenth Amendment, because, while the law of the state required all property to be taxed at its fair cash value, there was a uniform and general undervaluation of other property, but the company's property was taxed at its full value. There was conflicting testimony as to the valuations, most of the members of the board testifying that they tried in good faith to reach fair cash values. Held that:

The court will not intervene merely on the ground of a mistake in judgment on the part of the officer to whom the duty of assessment was entrusted by the law.

It is not beyond the power of a state, so far as the federal Constitution is concerned, to tax the franchise of a corporation at a different rate from the tangible property in the state.

Where the only constitutional ground on which the complainant can come into the circuit court obviously fails, the court should be very cautious in interfering with the state's administration of its taxes upon other considerations which would not have given it jurisdiction.

The facts are stated in the opinion. chanroblesvirtualawlibrary

Page 196 U. S. 604

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