Beers v. Glynn

Background

Emily M. Lord, a woman who lived in Morristown, New Jersey, died in 1892 owning both real estate in New York and personal property held in a New York safe-deposit company. New York’s 1887 law imposed a tax on property that passed by will or intestate if the property or part of it was within the State. The heirs challenged the tax, arguing that treating nonresidents who owned land in New York differently from those who had only personal property there denied them equal protection under the Constitution.

Reasoning

The Court examined the statute and earlier New York cases, including Matter of Embury where a nonresident with only personal property in New York faced no valid method for assessment and collection of the tax. The Court explained that the State may lawfully tax certain classes differently and may provide distinct procedures for different types of property. Because the law authorized taxing property tied to real estate in New York and provided a tribunal to assess it, the differing treatment did not, by itself, violate equal protection. The Court emphasized the wide authority states have to select subjects and methods of taxation.

Real world impact

As applied, New York may collect the inheritance tax from estates of nonresidents when the decedent owned real estate in the State. Estates with only personal property in New York may escape taxation if the statute provides no mechanism to assess and collect the tax. The Court affirmed the lower-court judgment upholding the tax.