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Some land in the territory of Minnesota was set aside by Congress for the use of railroads.
Territorial legislation exempted such property from taxation until the land was sold.
The original company to whom some land had been granted had failed to build a railroad, and the
property was then conveyed to Winona. Winona later sold interests in the property. After Minnesota
became a state, the legislature attempted to assess and tax for past taxes due all real property not on
the tax rolls.
The Supreme Court addressed two questions:
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Had the state of Minnesota, in disregard of Article
1 §10, cl. 1 of the Constitution of the United States, passed any law impairing the obligation
of contracts?
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Were the tax proceedings in violation of that clause of the Fourteenth
Amendment which prohibits a state from depriving any person of property without due process of
law?
The Court ruled that no contracts had been impaired, and that Minnesota statutes provided ample
procedural due process.
Full Text: Winona and St. P. Land
Co. v. State of Minnesota, 159 U.S. 526 (1895) |