First National Bank of Greeley v. Board of County Commissioners

Background

A national bank delivered the state-required list of its shares and shareholders to the county assessor. The assessor set the bank shares at full market value while valuing most other county property much lower. The State Tax Commission ordered a county-wide increase, so the bank’s assessed value rose substantially for 1913 and 1914. The bank paid the tax under protest and later sought a refund. It did not pursue available correction or equalization procedures with the county boards and state tax agency before suing. The lower court dismissed the bank’s complaint, and that dismissal was challenged up to this Court.

Reasoning

The key question was whether the bank could press its constitutional and statutory objections in court without first using state administrative procedures. Relying on the Colorado Supreme Court’s interpretation of state law, the Court held that administrative remedies were in fact available and that the bank had failed to use them. Because the bank did not exhaust those remedies, the Court would not consider the merits of its claims about unfair taxation or constitutional violations. The Court therefore affirmed the dismissal and left the tax collection intact.

Real world impact

This decision tells banks and other taxpayers they generally must try the administrative processes the state provides before bringing federal lawsuits about tax assessments. The ruling is procedural: it does not decide whether the assessment violated the Constitution. If a taxpayer first pursues and is denied adequate relief in the state process, it may still seek judicial review afterward.