United States Supreme Court Cases & Opinions

U.S. Supreme Court

Indiana Mfg. Co. v. Koehne, 188 U.S. 681 (1903)

Indiana Manufacturing Company v. Koehne

No. 177

Argued October 21, 1902

Decided February 23, 1903

188 U.S. 681

Syllabus

Certain taxes having been assessed against complainant, an Indiana corporation, pursuant to a law of Indiana upon the value of letters patent owned by it, an action was brought against the collector to enjoin the collection of such taxes, the appeal to equity being founded on the grounds: (1) That the assessment constituted a cloud upon title; (2) that there was no adequate remedy at law; (3) that a multiplicity of suits would be avoided; (4) that it would prevent irreparable injury to complainant. Held:

(1) That, in the absence of any statute making the assessment upon shares a lien on the real estate and of any averment that the company owned any real estate, no cloud upon title is made apparent.

(2) That the statute of Indiana provides a proceeding for the recovery of taxes wrongfully assessed, and as it does not appear that such statute has been repealed, an adequate remedy at law exists.

(3) That the procedure under such statute would not involve a multiplicity of suits.

(4) That where a plain and adequate remedy is given for the recovery of taxes illegally assessed no irreparable injury can be inferred from general statements in the absence of the averment of specific facts from which the court can see that irreparable injury would be a natural and probable result.

Equitable jurisdiction of a federal court cannot be maintained except on a ground recognized by the federal courts, and the mere fact that the action involved the taxing of letters patent does not give the federal courts jurisdiction in equity where no such recognized ground appears.

The case is stated in the opinion of the court.

Page 188 U. S. 682