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Tyler, 94, owed about $15,000 in taxes and penalties. The county sold her condo for $40,000 and kept the surplus, as the law allows in Minnesota, the District of Columbia and about a dozen other states.
But the Supreme Court, in a unanimous decision written by Chief Justice John G. Roberts Jr., said Tyler could go forward with her claim that the action violates the Constitution’s prohibition against the taking of property without just compensation.
“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,” Roberts wrote. “The taxpayer must render unto Caesar what is Caesar’s, but no more.”
Roberts rejected the county’s argument that Tyler had no property interest protected by the Constitution when she fell behind in her taxes.
“History and precedent say otherwise,” he wrote. “The County had the power to sell Tyler’s home to recover the unpaid property taxes. But it could not use the toehold of the tax debt to confiscate more property than was due.”
Because it found Tyler had a plausible claim of taking, the court did not reach a second issue in the case — whether the action violated the constitutional protection against excessive fines.
The Pacific Legal Foundation, a property-rights group representing Tyler, calls what Hennepin County did “equity-stealing.”
At oral argument, a lawyer for the organization told the court that if it upheld the Minnesota law, there would be a question about how much excess money a government could keep.
She said there is a Michigan case in which a $25,000 home was taken over an “$8.41 tax delinquency,” and she offered additional examples from Nebraska and elsewhere.
The case is Tyler v. Hennepin County.
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