United States Supreme Court Cases & Opinions

U.S. Supreme Court

Rowley v. Chicago & Northwestern Ry. Co., 293 U.S. 102 (1934)

Rowley v. Chicago & Northwestern Railway Co.

No. 9

Argued October 10, 1934

Decided November 5, 1934

293 U.S. 102

Syllabus

1. The Court is reluctant to place constructions upon state statutes of doubtful meaning, or to decide other questions of state law as to which there may be substantial controversy, in advance of decision by the state courts of last resort. P. 293 U. S. 104.

2. The ascertainment of the value of a railway system is not a matter of arithmetical calculation, and is not governed by any fixed and definite rule. Facts of great variety and number, estimates that are exact and those that are approximations, forecasts based on probabilities and contingencies, have bearing and properly may be taken into account to guide judgment in determining what is the money equivalent -- the actual value -- of the property. P. 293 U. S. 109.

3. An apportionment of system value of a railroad for taxation in one of several States traversed by its lines cannot be adjudged arbitrary merely because the mileage basis was used, although the average value per mile in that State was much less than for the system as a whole, where the mileage ratio was applied not singly, but combined with others, such as the ratios of the traffic units, use of rolling stock, and average of gross and net operating revenue in that State to the system totals, where the computation was tested by other criteria, such as the relations between cost of reproduction less depreciation of the local property and system value and between operating net revenues derived from that property and those earned by the system, and where there is nothing to show that the assessment was excessive. P. 293 U. S. 110.

Page 293 U. S. 103

4. Overvaluation by state tax officials resulting from error of judgment will not support a claim of discrimination. There must be something that amounts to an intention, or the equivalent of fraudulent purpose, to disregard the fundamental principle of uniformity. P. 293 U. S. 111.

5. Upon finding in an injunction suit that a state tax violates the equal protection clause of the Fourteenth Amendment because of discrimination in assessment, the federal court should leave the State free to reassess; it is without jurisdiction to fix the base and amount of the tax that may be lawfully exacted . P. 293 U. S. 112.

68 F.2d 527 reversed.

Certiorari, 292 U.S. 618, to review the affirmance of a decree of the District Court holding state taxes on the Railway Company's property in Wyoming arbitrary and excessive and enjoining collection upon the condition that the Company pay taxes on a reduced valuation made by the court.