St. Louis & Southwestern Railway Co. v. Nattin

Background

A railroad company that owned track in Bossier Parish, Louisiana, and stock in the bridge company sued to stop collection of a 1926 property tax. The local governing body, the parish police jury, had created a Consolidated Road District, issued bonds to build a highway, and levied an ad valorem tax to pay those bonds. A specially constituted three-judge district court dismissed the railroad’s bill and assessed costs and damages against it, and the railroad appealed to this Court.

Reasoning

The core question was whether the parish lawfully created the road district and could collect a general property tax that included the railroad’s property. The Court said the railroad’s complaints lacked merit. It noted that the railroad had opportunities under local procedures to object to valuation and the plan, and that prior decisions establish a taxpayer hearing is not always required. The Court found nothing in Louisiana’s constitution barring collection of the 1926 tax. It also held that a general ad valorem tax on all property, including property owned by carriers engaged in interstate commerce, is permissible and does not amount to unlawful regulation of interstate commerce.

Real world impact

The ruling lets the parish collect the assessed 1926 tax to help pay bond installments and affirms that local governments can fund road districts through general property taxes that include rail property. The decision rejects the railroad’s attempt to block tax collection by injunction and relies on established rules about taxing property used in interstate commerce.