"The Takings Clause does not itself define property. Phil-
lips v. Washington Legal Foundation, 524 U. S. 156, 164 (1998). For that, the Court draws on “existing rules or un-
derstandings” about property rights. Ibid. (internal quota-
tion marks omitted). State law is one important source.
Ibid.; see also Stop the Beach Renourishment, Inc. v. Flor-
ida Dept. of Environmental Protection, 560 U. S. 702, 707
(2010). But state law cannot be the only source. Otherwise,
a State could “sidestep the Takings Clause by disavowing
traditional property interests” in assets it wishes to appro-
priate. Phillips, 524 U. S., at 167; see also Webb’s Fabulous
Pharmacies, Inc. v. Beckwith, 449 U. S. 155, 164 (1980);
Hall v. Meisner, 51 F. 4th 185, 190 (CA6 2022) (Kethledge,
J., for the Court) (“[T]he Takings Clause would be a dead
letter if a state could simply exclude from its definition of
property any interest that the state wished to take.”). So
we also look to “traditional property law principles,” plus
historical practice and this Court’s precedents. Phillips,
524 U. S., at 165–168; see, e.g., United States v. Causby, 328
U. S. 256, 260–267 (1946); Ruckelshaus v. Monsanto Co.,
467 U. S. 986, 1001–1004 (1984)."
"But it could not use the toehold of the tax debt
to confiscate more property than was due. By doing so, it
effected a “classic taking in which the government directly
appropriates private property for its own use.” Tahoe-Si-
erra Preservation Council, Inc. v. Tahoe Regional Planning
Agency, 535 U. S. 302, 324 (2002) (internal quotation marks
and alteration omitted). Tyler has stated a claim under the
Takings Clause and is entitled to just compensation."
"B
The principle that a government may not take more from
a taxpayer than she owes can trace its origins at least as far
back as Runnymeade in 1215, where King John swore in
the Magna Carta that when his sheriff or bailiff came to
collect any debts owed him from a dead man, they could re-
move property “until the debt which is evident shall be fully
paid to us; and the residue shall be left to the executors to
fulfil the will of the deceased.”
"The consensus that a government could not take more
property than it was owed held true through the passage of
the Fourteenth Amendment. States, including Minnesota,
continued to require that no more than the minimum
amount of land be sold to satisfy the outstanding tax debt.2"
"Thirty-six States and the Federal Government require that
the excess value be returned to the taxpayer."
"“[t]o withhold the surplus from the owner would be
to violate the Fifth Amendment to the Constitution and to
deprive him of his property without due process of law, or
to take his property for public use without just compensa-
tion.” Id., at 150."
"But “property rights cannot
be so easily manipulated.” Cedar Point Nursery v. Hassid,
594 U. S. ___, ___ (2021) (slip op., at 13) (internal quotation
marks omitted). Minnesota may not extinguish a property
interest that it recognizes everywhere else to avoid paying
just compensation when it is the one doing the taking. Phil-
lips, 524 U. S., at 167."
"The Takings Clause “was designed to bar Government
from forcing some people alone to bear public burdens
which, in all fairness and justice, should be borne by the
public as a whole.” Armstrong, 364 U. S., at 49. A taxpayer
who loses her $40,000 house to the State to fulfill a $15,000
tax debt has made a far greater contribution to the public
fisc than she owed. The taxpayer must render unto Caesar
what is Caesar’s, but no more.
Because we find that Tyler has plausibly alleged a taking
under the Fifth Amendment, and she agrees that relief un-
der “the Takings Clause would fully remedy [her] harm,”
we need not decide whether she has also alleged an exces-
sive fine under the Eighth Amendment. Tr. of Oral Arg. 27.
The judgment of the Court of Appeals for the Eighth Circuit
is reversed.
It is so ordered."
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