Myles Salt Co. v. Board of Comm'rs of Iberia and St. Mary Drainage Dist.

Background

The owner of Weeks Island, a high, rolling island in southwest Louisiana, sued to stop the sale of the property for unpaid drainage taxes. Local officials in Iberia and St. Mary Parishes organized the Iberia & St. Mary Drainage District under state law. The district voted a five-mill ad valorem tax for forty years to pay bonds. Weeks Island is far higher than surrounding low lands. The complaint says the island cannot be drained and has never received and never can receive any benefit from the drainage works. Local officials allegedly included the island only to raise revenue from its high assessment. The tax collector sought to advertise the land as delinquent for four years, about $2,000 plus penalties.

Reasoning

The core question was whether including property in a drainage district solely to tax it, when the property gains no direct or indirect benefit, is an arbitrary taking in violation of the Fourteenth Amendment’s due-process protection (the rule that property cannot be taken without fair legal process). The state courts had dismissed the case, saying courts should not question local decisions about district boundaries absent fraud. The Supreme Court held the petition’s allegations must be taken as true and that such an inclusion, if only to extract revenue and confer benefit on other lands, is arbitrary and amounts to confiscation. The Court reversed the state Supreme Court’s judgment.

Real world impact

The decision protects landowners from being forced into local improvement districts when they receive no benefit and are included solely to pay for other lands’ improvements. It prevents local authorities from using district rules as a device to tax a high-value property for the special advantage of neighbors. The ruling was sent back to the state courts for further proceedings consistent with this opinion.