Iowa v. Slimmer

Background

The State of Iowa asked this Court for permission to file a direct lawsuit to collect taxes from the estate of Abraham Slimmer, a man who died leaving large promissory notes and bonds. Although Iowa says Slimmer lived in Iowa, most of his securities were in Minnesota with his son and an associate, and Minnesota probate officials had taken possession and appointed a special administrator. Iowa sought to stop the Minnesota probate court from proceeding and to have the estate administered in Iowa so Iowa could assess and collect taxes.

Reasoning

The central question was whether Iowa could use this Court to enjoin, or block, ongoing Minnesota probate proceedings over property that was physically in Minnesota. The Court explained that Minnesota courts have authority to deal with property located within the State and may require inheritance taxes be paid there before transfers. Because the securities were in Minnesota and the Minnesota court had taken charge of the estate, the only real relief Iowa sought would have been an injunction against Minnesota’s court. The Court held that Iowa was not entitled to that relief and therefore denied permission to file the direct lawsuit.

Real world impact

As a result, Minnesota may continue to administer and tax the decedent’s property that was located in Minnesota. The decision prevents Iowa from using this Court to stop Minnesota’s probate administration in this case, and it leaves the Minnesota proceedings and any appeals in the state courts to run their course.