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U.S. Supreme Court

Berryman v. Whitman College, 222 U.S. 334 (1912)

Berryman v. Board of Trustees of Whitman College

No. 95

Argued December 13, 1911

Decided January 9, 1912

222 U.S. 334


The amount in controversy where the question is whether a contract of exemption from taxation has been impaired by subsequent legislation is measured by the value of the right to be protected, and not by a mere isolated element, such as the tax for a single year.

In this case, the jurisdictional value of amount in controversy held to exceed $2,000, although the actual tax, the collection whereof was sought to be enjoined on the ground that its imposition impaired the obligation of a legislative contract, was less than $2,000.

Cases in which the jurisdictional value of amount in controversy is limited to the single tax involved reviewed and distinguished.

The Act of March 2, 1867, 14 Stat. 426, now Rev.Stat., § 1889, prohibiting the granting by territorial legislatures of especial privileges related to conferring new privileges on existing corporations as well as to granting privileges in original charters, and the prohibition included all especial privileges such as exemption from taxation.

In construing a statute, the court must be controlled by the power chanroblesvirtualawlibrary

Page 222 U. S. 335

manifested by the act, and not by the motive which initiated it; the scope of the act may extend beyond the generating cause thereof.

The rule that exemption from taxation must be strictly construed against the exemption is as broad as the subject to which it relates; the rule applies not only to the extent of the legislative grant itself, but also to the power of the legislature to make it.

A contract for exemption from taxation is an especial privilege, and is nonetheless within the prohibition of § 1889, Rev.Stat., because granted to an educational institution; it cannot be regarded as beyond the prohibition because granted as an equivalent.

The fact that Congress failed to disapprove an act of a territorial legislature does not validate it if the act was passed in direct violation of a prohibitive provision in the organic act. Clayton v. Utah, 132 U. S. 632.

The facts, which involve the jurisdiction of the Circuit Court of the United States on the question of the amount involved and also the validity of an act of the Legislature of the Territory of Washington exempting property of an educational institution from taxation, are stated in the opinion. chanroblesvirtualawlibrary

Page 222 U. S. 342

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