Columbus & Greenville R. Co. v. Miller Ex Rel. Mississippi Levee Dist.

Background

The Mississippi Levee District’s State Tax Collector sued a small railroad, the Columbus & Greenville Railway, to collect a tax of $350 per mile under a 1914 Mississippi law. The railroad had paid $50 per mile under a 1926 amendment that set a $50 rate for any railroad that did not own more than twenty-five miles in the district; the railroad’s main line there was 18.41 miles. The Collector claimed the 1926 law was void because the bill was not published as required by the state constitution. The Mississippi courts reached conflicting rulings. Evidence the railroad offered to show the classification was reasonable was excluded at trial, and the State Supreme Court held the 1926 proviso was arbitrary and violated the Fourteenth Amendment, requiring payment at the higher rate.

Reasoning

The Supreme Court asked whether the mileage-based classification in the 1926 amendment was invalid on its face under the Fourteenth Amendment’s protections. The Court concluded that selecting mileage and creating a class for railroads with less than twenty-five miles within the district is a legitimate legislative choice and not inherently arbitrary. The Court noted that the excluded evidence, if considered, would not have undermined the statute and that the Collector, acting as a state official, could not invoke federal Fourteenth Amendment protection for an interest that belonged to private parties. Because no federal constitutional defect appeared on the statute’s face, the Court reversed the state court.

Real world impact

The decision allows the 1926 amendment’s lower $50-per-mile rate to stand for qualifying short-line railroads, relieving that railroad from the higher $350 charge. The ruling affirms legislative discretion to classify taxpayers by mileage for district levies and leaves other questions about the 1914 law undecided.