Charleston Federal Savings & Loan Assn. v. Alderson
324 U.S. 182 (1945)

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U.S. Supreme Court

Charleston Federal Savings & Loan Assn. v. Alderson, 324 U.S. 182 (1945)

Charleston Federal Savings & Loan Association v. Alderson

No. 400

Argued February 7, 1945

Decided February 26, 1945

324 U.S. 182

Syllabus

1. The validity of a state statute under the Federal Constitution does not appear to have been drawn in question in this suit in the state courts challenging tax assessments, and an appeal under § 237(a) of the Judicial Code as amended is unauthorized; but, under § 237(c), certiorari is granted, since appellants properly raised the question of the validity of the assessments under the equal protection clause of the Federal Constitution. Pp. 324 U. S. 184, 324 U. S. 187.

Page 324 U. S. 183

2. Even where the federal question has been properly raised and decided in the state courts, an appeal under § 237(a) maybe dismissed where appellants fail to attack a statute explicitly in their assignments of error here. P. 324 U. S. 187.

3. Since the equal protection clause of the Fourteenth Amendment does not operate to bar taxation which does not, in fact, bear unequally on persons or property of the same class, mere differences in modes of assessment not shown to produce such inequality are not forbidden. P. 324 U. S. 190.

4. Nor does the equal protection clause prohibit inequality in taxation which results from mere mistake or error in judgment of tax officials, or which is not shown to be the result of intentional or systematic undervaluation of some, but not all, of the taxed property in a single class. P. 324 U. S. 190.

5. The burden of establishing the unconstitutionality of assessments for taxation is upon the protestant. P. 324 U. S. 191.

6. Appellant loan associations failed to sustain the burden of showing that state tax officials, who assessed appellants' property for state taxation at its full value, denied to appellants the equal protection of the laws, guaranteed by the Fourteenth Amendment, by their mode of valuation, for taxation, of property of the same class belonging to other taxpayers. P. 324 U. S. 192.

126 W.Va. 506, 30 S.E.2d 513, affirmed.

Appeal from a judgment sustaining the validity of assessments for state taxation.

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