Smith v. Kansas City Title & Trust | |
---|---|
Argued January 6–8, 1920 Reargued October 14–15, 1920 Decided February 28, 1921 | |
Full case name | Smith v. Kansas City Title & Trust Company |
Citations | 255 U.S. 180 ( more ) 41 S. Ct. 243; 65 L. Ed. 577 |
Holding | |
Because of federal-question jurisdiction, the Court was allowed to rule that the Federal Farm Loan Act of 1916 was constitutional and that the District Court had jurisdiction to rule as such. | |
Court membership | |
| |
Case opinions | |
Majority | Day, joined by White, McKenna, Van Devanter, Pitney, Clarke |
Concurrence | Brandeis |
Dissent | Holmes, McReynolds |
Laws applied | |
Article III of the United States Constitution (Section II) |
Smith v. Kansas City Title & Trust Co., 255 U.S. 180 (1921), was a United States Supreme Court case that helped define the range and scope of federal question jurisdiction in state corporate law matters. [1] The case dealt with whether or not a district court had the power to uphold the constitutional validity of the Federal Farm Loan Act of 1916.
Charles E. Smith, a shareholder of Kansas City Title & Trust Company, challenged the company's investment in farm loan bonds. The plaintiff (Smith) sued by filing an action in the United States District Court for the Western District of Missouri. The suit was filed to prevent the state bank from buying the federal bonds, claiming that the Federal Farm Loan Act of 1916, the law in which the transaction was based on, was unconstitutional.
Kansas City Title & Trust Co. was authorized to invest funds in legal securities only. The plaintiff was against investing money into federal land bonds ($10,000 into bonds of the federal land banks and $10,000 into bonds of the joint-stock land banks [2] ) because he alleged that the Congress's undertaking to organize new banks, based on the Federal Farm Loan Act, was unconstitutional. [3] The Western District Court of Missouri ruled that the Federal Farm Loan act was constitutional, making it so the Kansas City Title & Trust Co. could invest in farm loan bonds. The plaintiff wanted further relief on the matter, so the case went to the Supreme Court.
Before stating the holding, it is important to explain what the Federal Farm Loan Act was, what federal-question jurisdiction is, and how they pertain to this case.
The Federal Farm Loan Act was instated to increase credit to rural farmers to help small farmers compete with large corporate farms. After the Act was passed, farmers could borrow up to 50% of the value of their land. Mortgage-backed bonds were issued. "The rate of interest on the mortgages could be no more than 1 percent higher than the rate of interest on the bonds. This spread covered the issuers' administrative costs, but did not lead to a significant profit. In addition, the maximum rate of interest on the bonds was 6 percent, ensuring that borrowing costs for farmers was often much lower than before the Act was passed." The Act led to the creation of new banks. The new law gave extra financial sympathy to farmers, as stated in a letter to the chair of the United States House Committee on Agriculture: "It was essential, however, that banking machinery be devised which would reach intimately into the rural districts, that it should operate on terms suited to the farmer's needs, and should be under sympathetic management." [4] The Act was signed into law by President Woodrow Wilson on July 17, 1916.
Charles Smith believed that Congress had overstepped its bounds in creating the Federal Farm Loan Act. "It was the contention of Smith, among other things, that although farm loan bonds purported to be tax exempt, Congress had exceeded its constitutional authority in providing for the creation of federal and joint-stock land banks with the power to issue tax-exempt bonds; and that therefore these bonds were improper securities for the investment of trust company funds." [5] Smith thought that Congress did not have the right to create new banks and issue tax exempt bonds. Similarly, Law Writer Charles Enslow challenged the Act prior to Smith stating "Congress only has the affirmative power to tax, not the authorization to exempt from taxation any State property. The Federal Farm Loan Bank is nothing more nor less than a corporation chartered by the National Government, and whose sole object is to secure from a certain class of people of the United States money to be loaned to another class of people at a reduced interest rate." [6] Enslow thought that the Act favored farmers over other specialized workers and thought that the government does not have the right to help one group of citizens while leaving others behind.
Federal courts have limited jurisdiction compared to state courts. Federal courts can only rule over cases with subject matter dealing with Congress or the Constitution. [7] Federal-question jurisdiction gives the federal court subject-matter jurisdiction to hear a civil case because the appellant has claimed a violation of the Constitution.
Federal-question jurisdiction was used by the Supreme Court to hear this case. By claiming the Federal Farm Loan Act unconstitutional, the appellant created a federal suit.
Was the District Court allowed to and correct in upholding the Constitutional validity of the Federal Farm Loan Act?
The court gave opinions on two separate matters: The District Court's jurisdiction and the Constitutionality of the Federal Farm Loan Act. [8]
The Court ruled that "even where a cause of action arises under state law, a federal court may have jurisdiction if it appears that the right to relief rests on the construction or application of a federal law." [9] Justice Day ruled that the District Court had jurisdiction, stating, "the general rule is that where it appears from the bill or statement of the plaintiff that the right to relief depends upon the construction or application of the Constitution or laws of the United States, and that such federal claim is not merely colorable, and rests upon a reasonable foundation, the District Court has jurisdiction under this provision." [10] So, since this case dealt with federal matters, the Supreme Court ruled that the District Court still has jurisdiction under certain circumstances.
The Supreme Court affirmed the District Court's decision that the Federal Farm Loan Act is, in fact, constitutional. "The provision of the Federal Farm Loan Act of July 17, 1916, amended January 18, 1918, making the Federal Land Banks and Joint Stock Land Banks established thereunder depositaries of public money when designated by the Secretary of the Treasury, authorizing their employment as financial agents of the government, requiring them to perform, as such depositaries and agents, such reasonable duties as may be laid upon them, and authorizing them to purchase government bonds justify their creation as an exercise of the constitutional power of Congress. The necessity for such federal agencies is for Congress to determine, and the motives actuating Congress in exercising its power to create them are not a subject for judicial scrutiny." [1]
Justice Holmes dissented because he thought that the issue did not "arise under" federal law. He did not think that the Supreme Court had jurisdiction because the cause of action was created by state law and not federal law.
The upholding of the Federal Farm Loan Act was a decision that improved the livelihood of many American farmers, increased the power of Congress, and helped better define federal-question jurisdiction.
After the supreme court ruling, one newspaper headline proclaimed, "Decision which Establishes Constitutionality of Agricultural Credit Act Declared Greatest Victory for Farmers. Tax Exempt Feature of Bonds is also Sustained, Many Millions of Dollars of Credit Forthcoming to Farmers." [11] Another newspaper wrote, "The decision is expected to aid greatly in relieving the financial distress now confronting agricultural interests. [12] The positive effect that the act had on farmers still holds true today, as one news article posted July 24, 2006 reads, "Leaders Celebrate 90 Years of Federal Farm Loan Act." [13]
Congress's ability to pass an act that created new banks for farmers that allowed tax exemptions was unprecedented. Also, the Supreme Court's ruling gave a new precedent for federal-question jurisdiction. The ruling for Smith v. Kansas City Title & Trust Co. took power from state law and gave power to federal law. By ruling on the constitutionality of the issue, the Supreme Court took a district case and made it federal. By doing so, the court redefined the boundaries for federal-question jurisdiction.[ neutrality is disputed ]
Federal jurisdiction refers to the legal scope of the government's powers in the United States of America.
The Sixteenth Amendment to the United States Constitution allows Congress to levy an income tax without apportioning it among the states on the basis of population. It was passed by Congress in 1909 in response to the 1895 Supreme Court case of Pollock v. Farmers' Loan & Trust Co. The Sixteenth Amendment was ratified by the requisite number of states on February 3, 1913, and effectively overruled the Supreme Court's ruling in Pollock.
Pollock v. Farmers' Loan & Trust Company, 157 U.S. 429 (1895), affirmed on rehearing, 158 U.S. 601 (1895), was a landmark case of the Supreme Court of the United States. In a 5-4 decision, the Supreme Court struck down the income tax imposed by the Wilson–Gorman Tariff Act for being an unapportioned direct tax. The decision was superseded in 1913 by the Sixteenth Amendment to the United States Constitution, which allows Congress to levy income taxes without apportioning them among the states.
The federal government of the United States is the national government of the United States, a federal republic located primarily in North America, composed of 50 states, five major self-governing territories, several island possessions, and the federal district and national capital of Washington, D.C., where most of the federal government is based.
In the law of the United States, diversity jurisdiction is a form of subject-matter jurisdiction that gives U.S. federal courts the power to hear lawsuits that do not involve a federal question. For a U.S. federal court to have diversity jurisdiction over a lawsuit, two conditions must be met. First, there must be "diversity of citizenship" between the parties, meaning the plaintiffs must be citizens of different U.S. states than the defendants. Second, the lawsuit's "amount in controversy" must be more than $75,000. If a lawsuit does not meet these two conditions, U.S. federal courts will normally lack the power to hear it unless it involves a federal question, and the lawsuit would need to be heard in state court instead.
The Supreme Court of the United States has interpreted the Case or Controversy Clause of Article III of the United States Constitution as embodying two distinct limitations on exercise of judicial review: a bar on the issuance of advisory opinions, and a requirement that parties must have standing.
The Taxing and Spending Clause, Article I, Section 8, Clause 1 of the United States Constitution, grants the federal government of the United States its power of taxation. While authorizing Congress to levy taxes, this clause permits the levying of taxes for two purposes only: to pay the debts of the United States, and to provide for the common defense and general welfare of the United States. Taken together, these purposes have traditionally been held to imply and to constitute the federal government's taxing and spending power.
Steward Machine Company v. Davis, 301 U.S. 548 (1937), was a case in which the U.S. Supreme Court upheld the unemployment compensation provisions of the Social Security Act of 1935, which established the federal taxing structure that was designed to induce states to adopt laws for funding and payment of unemployment compensation. The decision signaled the Court's acceptance of a broad interpretation of Congressional power to influence state laws.
Bob Jones University v. Simon, 416 U.S. 725 (1974), is a decision by the Supreme Court of the United States holding that Bob Jones University, which had its 501(c)(3) status revoked by the Internal Revenue Service for practicing "racially discriminatory admissions policies" towards African-Americans, could not sue for an injunction to prevent losing its tax-exempt status. The question of Bob Jones University's tax-exempt status was ultimately resolved in Bob Jones University v. United States, in which the court ruled that the First Amendment did not protect discriminatory organizations from losing tax-exempt status.
South Carolina v. Baker, 485 U.S. 505 (1988), was a United States Supreme Court case in which the Court ruled that section 310(b)(1) of the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA) does not violate the Tenth Amendment to the United States Constitution.
Merrell Dow Pharmaceuticals Inc. v. Thompson, 478 U.S. 804 (1986), was a United States Supreme Court decision involving the original jurisdiction of the federal district courts under 28 U.S.C. § 1331.
Springer v. United States, 102 U.S. 586 (1881), was a case in which the United States Supreme Court upheld the federal income tax imposed under the Revenue Act of 1864.
Boyer v. Boyer, 113 U.S. 689 (1885), was a suit in error brought in a state court of Pennsylvania for an injunction restraining the commissioners of Schuylkill County, Pennsylvania from levying a county tax for the year 1883 upon certain shares in the Pennsylvania National Bank, an association organized under the National Banking Act. The suit proceeds upon the ground that such levy violates the act of Congress prescribing conditions upon state taxation of national bank shares in this, that "other moneyed capital in the hands of individual citizens" of that county is exempted by the laws of Pennsylvania from such taxation. A demurrer to the bill was sustained and the suit was dismissed. Upon appeal to the Supreme Court of Pennsylvania, that judgment was affirmed on the ground that the laws of the state under which the defendants sought to justify the taxation were not repugnant to the act of Congress.
Tax protesters in the United States advance a number of constitutional arguments asserting that the imposition, assessment and collection of the federal income tax violates the United States Constitution. These kinds of arguments, though related to, are distinguished from statutory and administrative arguments, which presuppose the constitutionality of the income tax, as well as from general conspiracy arguments, which are based upon the proposition that the three branches of the federal government are involved together in a deliberate, on-going campaign of deception for the purpose of defrauding individuals or entities of their wealth or profits. Although constitutional challenges to U.S. tax laws are frequently directed towards the validity and effect of the Sixteenth Amendment, assertions that the income tax violates various other provisions of the Constitution have been made as well.
In United States law, the federal government as well as state and tribal governments generally enjoy sovereign immunity, also known as governmental immunity, from lawsuits. Local governments in most jurisdictions enjoy immunity from some forms of suit, particularly in tort. The Foreign Sovereign Immunities Act provides foreign governments, including state-owned companies, with a related form of immunity—state immunity—that shields them from lawsuits except in relation to certain actions relating to commercial activity in the United States. The principle of sovereign immunity in US law was inherited from the English common law legal maxim rex non potest peccare, meaning "the king can do no wrong." In some situations, sovereign immunity may be waived by law.
The Supremacy Clause of the Constitution of the United States establishes that the Constitution, federal laws made pursuant to it, and treaties made under its authority, constitute the "supreme Law of the Land", and thus take priority over any conflicting state laws. It provides that state courts are bound by, and state constitutions subordinate to, the supreme law. However, federal statutes and treaties must be within the parameters of the Constitution; that is, they must be pursuant to the federal government's enumerated powers, and not violate other constitutional limits on federal power, such as the Bill of Rights—of particular interest is the Tenth Amendment to the United States Constitution, which states that the federal government has only those powers delegated to it by the Constitution.
Bank Markazi v. Peterson, 578 U.S. ___ (2016), was a United States Supreme Court case that found that a law which only applied to a specific case, identified by docket number, and eliminated all of the defenses one party had raised does not violate the separation of powers in the United States Constitution between the legislative (Congress) and judicial branches of government. The plaintiffs, in the case had initially obtained judgments against Iran for its role in supporting state-sponsored terrorism, particularly the 1983 Beirut barracks bombings and 1996 Khobar Towers bombing, and sought execution against a bank account in New York held, through European intermediaries, on behalf of Bank Markazi, the Central Bank of the Islamic Republic of Iran. The plaintiffs obtained court orders preventing the transfer of funds from the account in 2008 and initiated their lawsuit in 2010. Bank Markazi raised several defenses, including that the account was not an asset of the bank, but rather an asset of its European intermediary, under both New York state property law and §201(a) of the Terrorism Risk Insurance Act. In response to concerns that existing laws were insufficient for the account to be used to settle the judgments, Congress added an amendment to a 2012 bill, codified after enactment as 22 U.S.C. § 8772, that identified the pending lawsuit by docket number, applied only to the assets in the identified case, and effectively abrogated every legal basis available to Bank Markazi to prevent the plaintiffs from executing their claims against the account. Bank Markazi then argued that § 8772 was an unconstitutional breach of the separation of power between the legislative and judicial branches of government, because it effectively directed a particular result in a single case without changing the generally applicable law. The United States District Court for the Southern District of New York and, on appeal, the United States Court of Appeals for the Second Circuit both upheld the constitutionality of § 8772 and cleared the way for the plaintiffs to execute their judgments against the account, which held about $1.75 billion in cash.
Davis v. Michigan, 489 U.S. 803 (1989), is a case in the Supreme Court of the United States holding that states may not tax federal pensions if they exempt their own state pensions from taxation. In the 1930s, the federal and state governments began to charge income tax on salaries paid to each other's employees. However, reciprocal treatment was required under the doctrine of intergovernmental immunity. The Court's ruling extended the reciprocity to pensions, since they are a form of deferred compensation for services previously rendered by an employee.
Patchak v. Zinke, 583 U.S. ___ (2018), is a United States Supreme Court case in which the Court upheld the Gun Lake Trust Land Reaffirmation Act, which precludes federal courts from hearing lawsuits involving a particular parcel of land. Although six Justices agreed that the Gun Lake Act was constitutional, they could not agree on why. In an opinion issued by Justice Thomas, a plurality of the Court read the statute to strip federal courts of jurisdiction over cases involving the property and held that this did not violate Article III of the U.S. Constitution. In contrast, Justices Ginsburg and Sotomayor, both of whom concurred in the judgment, upheld the Act as a restoration of the government's sovereign immunity. Chief Justice Roberts, writing for himself and Justices Kennedy and Gorsuch, dissented on the ground that the statute intruded on the judicial power, in violation of Article III.