Lands which a State had acquired by adjudication for nonpayment
of taxes were leased by it for a term limited to end if the lands
were redeemed by the former owner or sold by the State.
that a later statute, permitting redemption on terms
less onerous than those in force when the lease was made, did not
impair the lessee's rights under the contract clause of the
Constitution or the due process and equal protection clauses of the
Fourteenth Amendment. P. 297 U. S.
182 La. 405, 162 So. 26, affirmed.
Appeal from a judgment affirming the dismissal of a suit in
which a mandamus was sought to cancel certificates of redemption of
land from tax sales, and an injunction against assertions of title
Appellant is a sublessee of lands leased by the State of
Louisiana in 1924 to the Terre aux Boeufs Drainage District. The
lands had become the property of the State by an adjudication for
unpaid taxes of 1911 to 1923. The lease by the State contained a
clause that the lease would end in case the lands were redeemed by
the former owner or sold by the State. At the time the lease and
Page 297 U. S. 120
were made, the lands could be redeemed only by payment of all
taxes, penalties, and interest due at the date of redemption. By a
subsequent statute, Act No. 161 of 1934, the Legislature of
Louisiana permitted redemption on different and less onerous terms
-- that is, by the payment, on an installment basis, of the actual
taxes for which the property had been adjudicated to the State.
Under that statute, certificates for the redemption of the lands in
question were issued by the register of the state land office.
Appellant then sought mandamus to compel the cancellation of the
certificates upon the ground that the Act of 1934 violated the
Constitution of the United States in that the act impaired the
obligation of appellant's contract of lease, deprived appellant of
its property without due process of law, and denied to appellant
the equal protection of the laws. Judgment against the appellant
was affirmed by the Supreme Court of the State. That court decided
that there was no impairment of the contract, as the clause in the
original lease, making it subject to redemption, was
"free of ambiguity and without limitation as to the conditions
under which the properties embraced in the lease might be redeemed
or sold or the price to be paid therefor."
State ex rel. Violet Trapping Co. v. Grace,
405, 162 So. 26, 28.
While this Court, when the contract clause of the Federal
Constitution is invoked, may determine for itself the meaning and
effect of the contract (Larson v. South Dakota,
278 U. S. 429
278 U. S. 433
United States Mortgage Co. v. Matthews, 293 U.
, 293 U. S.
), we find no reason for disagreeing with the
conclusion reached by the state court. The questions sought to be
raised under the due process and equal protection clauses of the
Fourteenth Amendment are without merit. Bachtel v. Wilson,
204 U. S. 36
204 U. S. 41
Rast v. Van Deman, 240 U. S. 342
240 U. S. 357
Sproles v. Binford, 286 U. S. 374
286 U. S. 396
The judgment is