Violet Trapping Co. v. Grace

Background

A company that held a sub-lease challenged a state process for redeeming tax-adjudicated lands. The State of Louisiana had leased the land in 1924 after it became state property through tax adjudication for unpaid taxes from 1911 to 1923. The original lease said the lease would end if the land were redeemed by the former owner or sold by the State. Initially redemption required paying all taxes, penalties, and interest at once. In 1934, the Louisiana legislature passed Act No. 161 allowing redemption on easier terms by paying the actual taxes in installments; the State Land Office then issued redemption certificates.

Reasoning

The company asked a court to cancel those certificates, arguing the 1934 law unlawfully changed its lease, took its property without fair process, and denied equal protection. The Louisiana Supreme Court found the lease’s redemption clause was clear and allowed redemption without limiting the conditions for redemption or sale. This Court reviewed the issue and agreed with the state court. It concluded the 1934 law did not unlawfully impair the lease and rejected the due process and equal protection claims as without merit. The judgment against the sub-lessee was affirmed.

Real world impact

The ruling leaves Act No. 161’s installment redemption procedure and the issued certificates intact. Former owners can redeem tax-adjudicated land under the easier terms the statute provides, and sub-lessees cannot use the Constitution to cancel those redemption certificates in this situation. The decision confirms that, on these facts, changing redemption terms did not invalidate the existing lease obligations.