May 25, 2023
Today, in a unanimous opinion authored by Chief Justice John Roberts, the U.S. Supreme Court rendered a decision for 94-year-old Geraldine Tyler in Tyler et al, v. Hennepin County et al, reversing an earlier ruling from the United States Court of Appeals for the Eighth Circuit.
The case arose in Hennepin County, Minnesota, after Tyler had been forced to vacate her condominium in 2010, moving into a senior community for safety concerns. Due to the relocation, she neglected to pay the property taxes on the property, which led to the County seizing her asset, foreclosing and selling the property for $40,000, and unjustly retaining all the proceeds from the sale – though the value of the property far exceeded her tax debt and associated interest and fees (which were approximately $15,000).
Ms. Tyler argued that Hennepin County’s refusal to return the excess sale proceeds to her was a taking without just compensation as stipulated by the Fifth Amendment. The U.S. Supreme Court agreed with her position.
Attorney General Sean D. Reyes led an Amicus Brief to the U.S. Supreme Court on behalf of Ms. Tyler for the States of Utah, Arkansas, Kansas, Kentucky, Louisiana, North Dakota, Texas, and West Virginia. The States argued that private property rights are essential to a free society, and when governments violate those rights, they destabilize the public’s trust in and respect for the system under which they live; and that the practice in a minority of states of confiscating surplus proceeds from a foreclosure sale, after the relevant delinquent taxes and fees are recouped, is just such a violation of these rights.
As Chief Justice Roberts wrote for the Court, “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.”