You are viewing a free summary from Descrybe.ai. For citation checking, legal issue analysis, and other advanced tools, explore our Legal Research Toolkit — not free, but close.

Carter v. Greenhow

Citations: 114 U.S. 317; 5 S. Ct. 928; 29 L. Ed. 202; 1885 U.S. LEXIS 1763Docket: 590

Court: Supreme Court of the United States; April 19, 1885; Federal Supreme Court; Federal Appellate Court

Narrative Opinion Summary

This case involves a trespass action initiated by a property owner against a state treasurer who seized the owner's property to satisfy unpaid taxes. The owner had attempted to pay the taxes using coupons from state-issued bonds, a payment method authorized by a 1879 legislative act. However, the treasurer refused to accept these coupons, citing a subsequent act mandating tax payments in specified currency forms. The owner claimed that this refusal constituted a violation of his constitutional rights, specifically regarding the impairment of contractual obligations as prohibited by Article 1, Section 10 of the U.S. Constitution. The federal court's jurisdiction was invoked under statutes allowing for claims of constitutional rights deprivation. The court concluded that while the issue was framed as a constitutional rights violation, the plaintiff failed to seek judicial remedies against the state law's enforcement. As such, the court affirmed the lower court's judgment, finding no valid cause of action under the relevant statutes, and emphasizing that judicial review of state decisions is the remedy provided by Congress for such claims. Consequently, the judgment for the defendant was upheld.

Legal Issues Addressed

Constitutional Rights and State Law Conflict

Application: The plaintiff argued that the refusal to accept coupons for tax payments, as allowed by state law, violated his constitutional rights.

Reasoning: The plaintiff claims violate the U.S. Constitution and are therefore void. The plaintiff argues that by refusing to accept tendered payment in coupons and money and seizing his property, the defendant infringed upon a constitutional right.

Contractual Obligations Under the Constitution

Application: The plaintiff's rights, stemming from a state contract, are indirectly protected by the constitutional prohibition against state laws impairing contractual obligations.

Reasoning: The constitutional basis for these rights is found in Article 1, Section 10, which prohibits states from impairing contractual obligations.

Federal Jurisdiction in Constitutional Rights Cases

Application: Federal courts have the jurisdiction to hear cases alleging deprivation of constitutional rights under state laws.

Reasoning: Federal jurisdiction is established by the sixteenth clause of section 629 of the Revised Statutes, allowing U.S. circuit courts to hear cases involving deprivation of constitutional rights under state laws, regardless of the monetary value or citizenship of the parties.

Judicial Review as a Remedy

Application: The court emphasized that the remedy provided by Congress for enforcing rights involves judicial review of state court decisions.

Reasoning: The only remedy Congress has provided for enforcing these rights involves judicial review of state court decisions.

Requirement for Judicial Remedies

Application: The plaintiff did not pursue available judicial remedies to challenge the alleged unconstitutional actions.

Reasoning: The plaintiff did not demonstrate that he was deprived of this right, as he did not pursue judicial remedies to challenge the alleged unconstitutional actions.