Rogers v. Hennepin County
240 U.S. 184 (1916)

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U.S. Supreme Court

Rogers v. Hennepin County, 240 U.S. 184 (1916)

Rogers v. Hennepin County

No. 104

Argued December 6, 1916

Decided February 21, 1916

240 U.S. 184

Syllabus

Where the state court does not decide against plaintiff in error upon an independent state ground, but, deeming the federal question to be before it, actually entertains it and decides it adversely, this Court has jurisdiction to review the final judgment under § 237, Jud.Code.

The state court having stated in a per curiam opinion that this case was controlled by the judgment in another similar case in which it entertained and decided the same federal questions as to constitutionality of the tax sought to be enjoined, held that, although there may have been other questions involved in this case, the judgment did not rest upon an independent state ground.

Memberships in exchanges, such as those involved in this action, are property notwithstanding restrictions upon their use, and nothing in the federal Constitution prevents their being taxed.

Whether memberships in exchanges are in fact taxable under the state statutes is a matter of local law.

Memberships in an incorporated exchange, as property of the respective members, are distinct from the assets of the corporation, and taxing the members on their memberships and the corporation on its assets does not amount to double taxation.

The correct valuation of property is a matter for the taxing officials; and, where there is no charge of denial of opportunity to be heard, this Court does not sit to review their judgment.

Memberships in an Exchange represent rights and privileges to be exercised at the exchange where located, and it is competent for a state to fix the situs of memberships of both residents and nonresidents for the purpose of taxation at the place where the exchange is located, and, in so doing, it does not deprive nonresident members of their property without due process of law.

The state has a broad discretion as to tax exemptions, and the taxation of memberships in association conducting exchanges in which business transactions are conducted for profit does not deny equal protection of the laws because memberships in other associations not conducting business exchanges and where there are manifest

Page 240 U. S. 185

distinction are not also taxed; the classification has a reasonable basis.

124 Minn. 539 affirmed.

The facts, which involve the constitutionality, under the Fourteenth Amendment, and the construction, of statutes of Minnesota and proceedings thereunder levying taxes upon memberships in trade exchanges in that state, are stated in the opinion.

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