Bradley v. City of Richmond

Background

A business owner who worked as a private banker in Richmond was convicted for carrying on that business without a license under a city ordinance. The ordinance listed many occupations and required payment of a special license tax; occupations were to be divided into thirteen classes with different tax amounts, from $800 down to $10. The state courts upheld the law, and the owner argued to the United States Supreme Court that the scheme denied equal protection and due process under the Fourteenth Amendment.

Reasoning

The core question was whether letting a city committee classify occupations and set different license amounts violated constitutional fairness guarantees. The Court said the State may delegate that classification power so long as it respects due process and equal protection. The ordinance included safeguards: a public filing, newspaper notice, hearings before the finance committee, and an appeal to the full city council. The owner failed to prove that his business was exactly the same as those put in lower-tax classes; evidence showed differences in types of loans. He also did not pursue the available local hearing and council review, so the Court would not intervene to correct an administrative error that had not been challenged locally.

Real world impact

Cities may assign occupations to tax classes with administrative procedures, and businesses must use local notice, hearings, and council appeals to challenge classifications. If those local processes are exhausted and injustice remains, judicial review remains available.

Dissents or concurrances

Justice Lamar agreed with the Court’s result, concurring in the outcome.