League v. Texas

Background

In 1897 Texas passed a law letting the State collect unpaid property taxes through court proceedings instead of relying only on the tax collector’s administrative sale. A landowner admitted that valid taxes had been levied and not paid, and said earlier collector sales had been made and bid in for the State. He argued the prior sales fixed the State’s rights and that the new law unlawfully upset that status and denied him constitutional protections.

Reasoning

The Court explained that a taxpayer has no vested right in a particular way a State chooses to collect taxes. A State may change remedies and apply a new method to taxes already delinquent, unless a specific constitutional right is infringed. The Court accepted that the State could waive rights it gained from the earlier collector’s sale and could set conditions for such a waiver. It also held that reasonable costs for officials and retroactive interest on unpaid taxes are permissible. The Court found no violation of the Federal Constitution in applying the 1897 law to these delinquent taxes and affirmed the Texas courts’ rulings.

Real world impact

This ruling lets a State convert older administrative tax procedures into court-based collection actions, require payment of interest from the time of delinquency, and include ordinary fees and costs for collection. Landowners who have unpaid taxes cannot rely solely on earlier collector sales to avoid later judicial enforcement once the State adopts a new collection method.