Ward v. Love County
253 U.S. 17 (1920)

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U.S. Supreme Court

Ward v. Love County, 253 U.S. 17 (1920)

Ward v. Board of Commissioners of Love County

No. 224

Submitted March 11, 1920

Decided April 25, 1920

253 U.S. 17

Syllabus

The jurisdiction of this Court to review a judgment of a state court the effect of which is to deny a federal right cannot be avoided by placing such judgment on nonfederal grounds which are plainly untenable. P. 253 U. S. 22.

Certain allotments belonging to Indians in Oklahoma, which by federal right were exempt from taxation, were assessed by county officials, while suits, of which they had full knowledge and in one of which they were defendants, were being litigated in behalf of all such allottees, to maintain the exemption (Choate v. Trapp, 224 U.S.

Page 253 U. S. 18

665), and, in response to demands, accompanied by threats of advertisement and sale which were carried out in other case, the allottees paid the taxes to avoid such sales and the imposition of heavy penalties, but did so under protest, denying the validity of the taxation. Held:

(1) That the payment were clearly made under compulsion, and that no statutory authority was necessary to enable or require the county to refund the money (p. 253 U. S. 23).

(2) The fact that part of the money, after collection, was paid over by the county to the state and other municipalities, and the absence of a state statute making the county liable for taxes so paid, did not alter the county's obligation to restore the full sums to the allottees. P. 253 U. S. 24.

The application of the state statute of limitations, not having been discussed by the state court, is not dealt with here or affected by the decision. P. 253 U. S. 25.

68 Okla. ___ reversed.

The case is stated in the opinion.

Primary Holding
State court decisions that involve any issues related to federal law may be subject to appeal to the U.S. Supreme Court.
Facts
Coleman Ward and 66 other Native Americans lived on land in Love County, Oklahoma that had been granted to them by the federal government. The original grant provided that the land would be non-taxable for the next 21 years, as long as it remained in the possession of the parties to whom it had been allotted. However, a decade later, Congress ruled that the land would be subject to taxes even if it were still in the possession of the allotted parties. When the County began to assess taxes on the land, Ward and the other Native Americans argued that they could not be constitutionally deprived of the vested property right that they had been granted through the tax exemption. During this period, other Native Americans in Oklahoma were bringing similar challenges to the loss of their tax-exempt status with regard to their land. The Supreme Court eventually ruled in their favor under the Fifth Amendment, holding that Oklahoma could not tax their lands.

Love County continued to demand that the Native Americans living there should pay the tax, and it threatened them with selling their property if they did not pay off the assessment. Some land belonging to other Native Americans actually was sold off by the County. Rather than face the loss of their land and an 18 percent penalty, Ward and the people living in the area paid their taxes. They then brought an action in state court to recover what they had paid, arguing that the payments were the product of coercion. After they prevailed in the state trial court, the Oklahoma Supreme Court denied them the right to recover the payments. It ruled that they had paid the taxes voluntarily and pointed out that the county already had paid the tax money to the state and municipal governments. When Ward and the other plaintiffs sought review by the U.S. Supreme Court, the County argued that certiorari would be improper because the Oklahoma Supreme Court had based its decision exclusively on state law.

Opinions

Majority

  • Willis Van Devanter (Author)
  • Edward Douglass White
  • Joseph McKenna
  • Oliver Wendell Holmes, Jr.
  • William Rufus Day
  • Mahlon Pitney
  • James Clark McReynolds
  • Oliver Wendell Holmes, Jr.
  • John Hessin Clarke

The appellate jurisdiction of the U.S. Supreme Court does not exist if the state court based its decision completely on state law issues. This is not the case here, since the tax exemption was a right granted to the plaintiffs by the federal government. Its potential removal thus presents an issue of federal law. While the state Supreme Court based its decision on finding that the taxes were paid voluntarily, this conclusion is clearly erroneous because it is undisputed that the defendant used coercive measures to force the plaintiffs to pay the taxes. Even though the defendant redistributed the funds among other state and local governments, it still needed to repay the funds because they were illegitimately obtained. The U.S. Supreme Court has the authority to reverse the judgment of the state Supreme Court because federal law is involved.

Case Commentary

The Supreme Court cannot have the power to review decisions based entirely on state law, since the state courts would not have the important power of final authority over their own matters. Federal and state systems must be separated to preserve state sovereignty.

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