Tyler v. Hennepin County
2023 United States Supreme Court case / From Wikipedia, the free encyclopedia
Tyler v. Hennepin County, 598 U.S. 631 (2023), was a United States Supreme Court case about government seizure of property for unpaid taxes, when the value of the property seized is greater than the tax debt. A unanimous court held that the surplus value is protected by the Fifth Amendment's Takings Clause.
Tyler v. Hennepin County | |
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Argued April 26, 2023 Decided May 25, 2023 | |
Full case name | Geraldine Tyler, on behalf of herself and all others similarly situated v. Hennepin County, and Daniel P. Rogan, Auditor-Treasurer, in his official capacity |
Docket no. | 22-166 |
Citations | 598 U.S. 631 (more) |
Argument | Oral argument |
Opinion announcement | Opinion announcement |
Case history | |
Prior | Motion to dismiss granted, 505 F.Supp.3d 879 (D. Minn. 2020); affirmed, 26 F.4th 789 (8th Cir. 2022); cert. granted (Jan 13, 2023) |
Questions presented | |
1. Whether taking and selling a home to satisfy a debt to the government, and keeping the surplus value as a windfall, violates the Takings Clause?2. Whether the forfeiture of property worth far more than needed to satisfy a debt plus, interest, penalties, and costs, is a fine within the meaning of the Eighth Amendment? | |
Holding | |
Hennepin County’s retention of the excess value of her home above her tax debt violated the Takings Clause of the Fifth Amendment. | |
Court membership | |
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Case opinions | |
Majority | Roberts, joined by unanimous |
Concurrence | Gorsuch, joined by Jackson |
Laws applied | |
U.S. Const. amends. V, XIV, Minn. Stat. §§ 280.29, 280.41, 282.08 |
Geraldine Tyler owed $15,000 in property taxes and other associated costs. Hennepin County, Minnesota foreclosed on her condominium, sold it for $40,000, and kept all of the money.[1][2]
Tyler sued the county, arguing that the $25,000 surplus home equity value was property that the county took away from her in violation of the Fifth Amendment and Eighth Amendment. The district court dismissed the case, ruling in favor of the county on all of Tyler's claims, and the United States Court of Appeals for the Eighth Circuit affirmed. Tyler petitioned to the Supreme Court, which agreed to review the case.[1][2]
The case was filed in 2019 as a class action by attorneys Charles Watkins, Garrett Blanchfield, Vildan Teske, and Roberta Yard.
On appeal, Christina Martin, an attorney with the Pacific Legal Foundation, joined Tyler's attorneys and represented Tyler as well as Kevin Fair, who had a similar case before the Supreme Court.[3]