Wayne County Board of Review v. Great Lakes Steel Corp.

1937-02-01
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Headline: Court affirms order blocking Michigan law that created a county review board as an improper local law, protecting property owners from that county’s new assessment review procedure.

Holding:

Real World Impact:
  • Prevents enforcement of the county board-of-review law for property assessments.
  • Protects property owners in the affected county from that assessment procedure.
  • Reinforces state ban on special local laws when a general law could apply.
Topics: property taxes, local laws, county government, state constitution

Summary

Background

A property owner sued to stop enforcement of a Michigan law that set up a county board to review property assessments. The law applied only where a county met a high population threshold and, in practice, affected Wayne County. The owner argued the statute was a local or special law in a case where a general law could apply, violating §30 of Article V of Michigan’s constitution. A three-judge federal district court agreed and issued a permanent order stopping the law from being used.

Reasoning

The central question was whether the statute was an impermissible local or special law when a general law could have covered the situation. The Supreme Court reviewed the district court’s decision about Michigan law and said it could not find error in that ruling. As a result, the Court affirmed the lower court’s decree, which means the court order blocking enforcement stands and the law was treated as invalid under the state constitution.

Real world impact

Property owners in the affected county are protected from enforcement of this specific county review board law for assessments. Local officials cannot use the statute to change assessment review procedures while the injunction remains in effect. The decision rests on Michigan’s state constitutional rule against local or special laws and does not create a new national rule; it affirms the lower court’s judgment in this dispute.

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