Tyler v. Hennepin County
Tyler v. Hennepin County (Docket 22-166) is a pending 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. The court will decide whether such a forfeiture violates the Fifth Amendment's protection against taking property without just compensation. The court will also decide whether it is an unconstitutional fine under the Eighth Amendment.
| Tyler v. Hennepin County | |
|---|---|
 | |
| Argued April 26, 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 |
| 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? | |
| Court membership | |
| |
| Laws applied | |
| U.S. Const. amends. V, VIII, 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]
Christina Martin, an attorney with the Pacific Legal Foundation, represented Tyler as well as Kevin Fair, who had a similar case before the Supreme Court.[3]
Background
In 1999, Geraldine Tyler purchased a condominium in North Minneapolis. For a decade, she lived in the condo and paid taxes on the property. In 2010, after a frightening altercation with a neighbor, Tyler sought to move into a safer community. Subsequently, she neglected to pay property taxes on her North Minneapolis condo.
In 2015, after years of property tax delinquency, Hennepin County seized Tyler's condo, foreclosed on it, and sold it for $40,000. Tyler had accrued a tax bill of $2,300 on the property, in addition to $13,200 of associated interest, fines, and penalties. Hennepin County retained all of the profits of the sale (about $25,000) and returned none of it to Tyler, pursuant to Minnesota law.
In 2019, Tyler filed a class action alleging that the taking of property worth far more than was needed to relieve a tax debt and retaining the profits violated the Takings Clause of the Fifth Amendment, the Excessive Fines Clause of the Eighth Amendment, and substantive due process. Tyler's case was dismissed by the district court in December 2020. On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the judgment of the lower court.
On August 19, 2022, Tyler petitioned the Supreme Court to hear her case. The court granted certiorari on January 13, 2023.
See also
- Austin v. United States (1993), a case about the Eighth Amendment and forfeiture
- United States v. Bajakajian (1998), another Eighth Amendment forfeiture case
References
- "Supreme Court takes up property 'theft' dispute over unpaid taxes". NBC News. January 13, 2023.
- "High court takes 8 new cases, 1 about a religious mailman". AP News. January 13, 2023.
- Martin, Christina. "Opinion | The Supreme Court Takes Up 'Home-Equity Theft'". WSJ. Retrieved 2023-04-21.