Looks like the Pacific Legal Foundation slam dunked the ball AGAIN, at the SCOTUS (9-0)! VERY Sympathetic Plaintiff.
Is the Ruling limited to taxpayer Plaintiffs only?....
Held: Tyler plausibly alleges that Hennepin County’s retention of the excess value of her home above her tax debt violated the Takings Clause.
Pp. 3–14.
(a) Tyler’s claim that the County illegally appropriated the $25,000
surplus constitutes a classic pocketbook injury sufficient to give her
standing. TransUnion LLC v. Ramirez, 594 U. S. ___, ___. Even if
there are debts on her home, as the County claims, Tyler still plausibly
alleges a financial harm, for the County has kept $25,000 that she
could have used to reduce her personal liability for those debts. Pp. 3–
4.
(b) Tyler has stated a claim under the Takings Clause, which pro-
vides that “private property [shall not] be taken for public use, without
just compensation.” Whether remaining value from a tax sale is prop-
erty protected under the Takings Clause depends on state law, “tradi-
tional property law principles,” historical practice, and the Court’s
precedents. Phillips v. Washington Legal Foundation, 524 U. S. 156,
165–168. Though state law is an important source of property rights,
it cannot be the only one because otherwise a State could “sidestep the Takings Clause by disavowing traditional property interests” in assets
it wishes to appropriate. Id., at 167. History and precedent dictate
that, while the County had the power to sell Tyler’s home to recover
the unpaid property taxes, it could not use the tax debt to confiscate
more property than was due. Doing so effected a “classic taking in
which the government directly appropriates private property for its
own use.” Tahoe-Sierra Preservation Council, Inc. v. Tahoe Regional
Planning Agency, 535 U. S. 302, 324 (internal quotation marks omit-
ted).
The principle that a government may not take from a taxpayer more
than she owes is rooted in English law and can trace its origins at least
as far back as the Magna Carta. From the founding, the new Govern-
ment of the United States could seize and sell only “so much of [a] tract
of land . . . as may be necessary to satisfy the taxes due thereon.” Act
of July 14, 1798, §13, 1 Stat. 601. Ten States adopted similar statutes
around the same time, and the consensus that a government could not
take more property than it was owed held true through the ratification
of the Fourteenth Amendment. Today, most States and the Federal
Government require excess value to be returned to the taxpayer whose
property is sold to satisfy outstanding tax debt.
The Court’s precedents have long recognized the principle that a tax-
payer is entitled to the surplus in excess of the debt owed. See United
States v. Taylor, 104 U. S. 216; United States v. Lawton, 110 U. S. 146.
Nelson v. City of New York, 352 U. S. 103, did not change that. The
ordinance challenged there did not “absolutely preclud[e] an owner
from obtaining the surplus proceeds of a judicial sale,” but instead
simply defined the process through which the owner could claim the
surplus. Id., at 110. Minnesota’s scheme, in comparison, provides no
opportunity for the taxpayer to recover the excess value from the State.
Significantly, Minnesota law itself recognizes in many other con-
texts that a property owner is entitled to the surplus in excess of her
debt. If a bank forecloses on a mortgaged property, state law entitles
the homeowner to the surplus from the sale. And in collecting past due
taxes on income or personal property, Minnesota protects the tax-
payer’s right to surplus. Minnesota may not extinguish a property in-
terest that it recognizes everywhere else to avoid paying just compensa-
tion when the State does the taking. Phillips, 524 U. S., at 167. Pp. 4–12.
(c) The Court rejects the County’s argument that Tyler has no prop-
erty interest in the surplus because she constructively abandoned her
home by failing to pay her taxes. Abandonment requires the “surren-
der or relinquishment or disclaimer of” all rights in the property, Rowe
v. Minneapolis, 51 N. W. 907, 908. Minnesota’s forfeiture law is not
concerned about the taxpayer’s use or abandonment of the property,
only her failure to pay taxes. The County cannot frame that failure as abandonment to avoid the demands of the Takings Clause. Pp. 12–14.
26 F. 4th 789, reversed.
ROBERTS, C. J., delivered the opinion for a unanimous Court. GOR-
SUCH, J., filed a concurring opinion, in which JACKSON, J., joined.
