Snapp v. Neal

Background

Sergeant Jesse E. Snapp, a serviceman stationed at Crystal Springs Air Force Base in Mississippi, bought a house trailer in Mississippi and moved it to a private trailer park near the base. He put the trailer on movable concrete blocks and lived in it as his home. He did not register, license, or pay taxes on the trailer in his home State of South Carolina. Mississippi imposed an ad valorem property tax on the trailer. Snapp sued, saying he was immune from that tax under the Soldiers' and Sailors' Civil Relief Act of 1940, which protects certain nonresident servicemembers from state motor-vehicle taxes. The Mississippi Supreme Court upheld the tax, saying the servicemember lost immunity by not paying home-state vehicle fees.

Reasoning

The Court considered whether the host State could treat a servicemember’s failure to pay home-state motor-vehicle fees as permission to impose an ad valorem tax. Relying on the companion decision in Buzará, the Court held that the federal statute allows a host State only to collect motor vehicle taxes that are true “licenses, fees, or excises” of the home State. An ad valorem property tax is not such a charge. Because ad valorem taxes do not qualify as the specified motor-vehicle "license, fee, or excise," the Mississippi levy could not stand. The Court therefore reversed the Mississippi Supreme Court. The Court did not decide whether the house trailer itself counts as a "motor vehicle" under the statute.

Real world impact

The decision prevents a host State from converting a servicemember’s failure to comply with home-state vehicle fee rules into authority to collect ad valorem property taxes under this statute. Nonresident military members who live in movable trailers may be shielded from similar state property taxes under the Act. The ruling follows the Court’s companion decision and leaves open some questions, such as whether a particular trailer counts as a motor vehicle for the statute.