Conroy v. Aniskoff

Background

An Army officer who served on active duty for many years bought a vacant lot in Maine in 1973, paid taxes for a decade, but missed local taxes in 1984–1986. The town followed state law and sold the property for unpaid taxes in 1986. The soldier sued, saying a federal law that tolls deadlines during military service prevented the town from perfecting title. Maine courts rejected his claim, and the case reached the Supreme Court to resolve conflicting lower-court interpretations.

Reasoning

The Court looked first at the plain language of the Soldiers’ and Sailors’ Civil Relief Act provision saying military service “shall not be included” when computing redemption periods. It found that phrase unambiguous and concluded Congress deliberately omitted any requirement that a service member show prejudice or hardship. The majority noted other parts of the law include prejudice requirements when Congress intended them, so §525 must be read as providing automatic tolling for the period of service. The Supreme Court reversed the Maine decision and ruled in favor of the service member. Justice Scalia agreed with the outcome but separately warned courts should stop consulting legislative history once a statute is clear.

Real world impact

The ruling means time spent on active duty pauses state redemption deadlines for property sold to collect taxes, and servicemembers do not have to prove that duty harmed their ability to redeem. That protection covers career military personnel as well as draftees. Congress, the Court observed, could amend the law if it believes the result is unfair.

Dissents or concurrances

Justice Scalia concurred in the judgment, urging that the Court rely only on the statute’s clear text and avoid legislative history in interpretation.