Hunter v. City of Pittsburgh

Background

A Pennsylvania law authorized one city to petition to consolidate with a neighboring city if a combined-election majority favored the merger. Pittsburgh petitioned, a combined vote favored consolidation even though a majority of Allegheny voters opposed it, and a state court entered a decree uniting the two cities. Citizens, voters, property owners, and taxpayers of Allegheny filed objections in state court and lost at each level before bringing federal claims to this Court.

Reasoning

The Court considered two federal claims: that the law impaired a contract between the city and its taxpayers and that it denied due process by letting the larger city override the smaller city’s voters and increase taxes. The Court rejected the novel idea that taxpayers have a contract shielding them from state changes in municipal government, and reiterated that a State may create, alter, or unite municipal corporations and their powers. The Court also noted a legal distinction between public governmental property and private property owned by a city, but found the record did not show Allegheny had proprietary property taken without due process. Because the federal claims were properly presented and not frivolous, the Court addressed them and overruled the assignments of error.

Real world impact

The ruling leaves in place the state-law process for city consolidation and lets the combined government and tax structure go forward. It limits federal constitutional protection for citizens who object to state decisions changing municipal boundaries or taxing arrangements, unless a clear record shows private property was taken without compensation. The judgment of the state court was affirmed.