Litchfield v. County of Webster - 101 U.S. 773 (1879)
U.S. Supreme Court
Litchfield v. County of Webster, 101 U.S. 773 (1879)
Litchfield v. County of Webster
101 U.S. 773
1. Wolsey v. Chapman, supra, p. 101 U. S. 755, reaffirmed.
2. This Court adhering to the construction given by the Supreme Court of Iowa to the revenue laws of that state touching the time when lands located or entered under the laws of the United States or purchased from the state, become taxable, holds that the lands, the title whereto by the joint resolution of Congress approved March 2, 1861, 12 Stat. 251, passed to bona fide purchasers of that state, were not subject to taxation prior to the year 1862.
3. Where the state claimed adversely to the true owner a part of said lands, and there was a controversy whether the title to the remainder had passed from the United States, and, on that account, the proper authorities of the state gave notice to the parties in interest that no legal steps would be taken to enforce the collection of the taxes until the title should be adjusted, held that the statutory interest, which is in the nature of a penalty, cannot be exacted for nonpayment of them within the time prescribed by law where the owner, on the adjustment of the title, offered to pay so much of them as was actually due, with interest thereon at the rate allowed by law for delay in the payment of ordinary debts, and his offer was refused.
4. A court of equity has, under such circumstances, the power to grant relief by enjoining the collection of such statutory interest.
Litchfield filed, Sept. 29, 1873, his bill of complaint against the County of Webster, Iowa, and Hutchinson, its treasurer, seeking to enjoin the collection of the taxes levied for 1859, 1860, 1861, 1862, 1863, 1864, 1865, and 1866 on lands whereof he claimed to be the owner. They amount to 32,602 92/100 acres, and are situate in that county in the alternate odd-numbered sections, within five miles of that part of the Des Moines River which is above the Raccoon Fork.
The principal of the taxes, when the case was submitted to the court below, was $10,174.76, and the penalty claimed for the nonpayment of them, $64,235.41, making a total of $74,410.17.
These lands are a portion of those which gave rise to a long protracted controversy of which Wolsey v. Chapman, supra, p. 101 U. S. 755, furnishes a complete history.
The facts which this suit involves are stated with sufficient fullness in the opinion of the Court.
The court below, considering the penalties prescribed by the revenue laws of Iowa, as in the nature of interest rather than as statutory penalties proper, held that the complainant, by reason of the acts of the state and its officers, was entitled to relief upon his paying the full amount of taxes from 1862 to 1866 inclusive, with annual interest thereon at the rate of six percent, and that the lands were not subject to taxation for the preceding years. A decree was entered accordingly, and each party appealed.