New York Ex Rel. Twenty-Third Street R. Co. v. New York State Bd. of Tax Comm'rs

Background

Several street railway companies and gas companies in New York brought appeals challenging actions by the State Board of Tax Commissioners. The companies included the Twenty-Third Street Railway Company, Central Crosstown Railroad Company, Consolidated Gas Company, New Amsterdam Gas Company, and the Coney Island and Brooklyn Railroad Company. Their lawyers included Elihu Root, William D. Guthrie, and Frank H. Platt. The State was represented by Attorney General Julius M. Mayer and Louis Marshall. These matters came to the United States Supreme Court on appeals from the New York Supreme Court; they were argued April 17–19, 1905, and decided May 29, 1905.

Reasoning

Justice Brewer delivered the opinion for the Court. The Court said these cases differed in some details from two related cases whose opinions had just been announced, but that the differences were not enough to remove them from the same legal approach. Because of that, the Court applied the reasoning of the immediately preceding opinions rather than announcing a new analysis. The result was that the Supreme Court affirmed the judgments that had been entered against the companies.

Real world impact

The practical effect is straightforward: the State Board of Tax Commissioners’ rulings and the lower courts’ judgments remain in force for these particular disputes. The companies did not obtain the relief they sought from the Supreme Court. These cases were argued at the same time as Metropolitan Street Railway Company v. New York and were decided by reference to closely related earlier opinions rather than through separate, lengthy new opinions.