Goldsmith v. George G. Prendergast Construction Co.

Background

A Construction Company sued in a St. Louis trial court to collect special tax bills issued for building a sewer in Manchester Road Sewer District No. 3. The company recovered a judgment against nearby property owners who owned land abutting Kingshighway Boulevard. Those owners complained because Tower Grove Park, a large tract owned by the city that also borders the boulevard, was not included in the sewer district or assessed. They argued that leaving the park out was arbitrary and denied them equal treatment and due process under the Fourteenth Amendment.

Reasoning

The central question was whether the city’s decision to include some properties and exclude others was arbitrary or fraudulent. The court noted that the city charter gave the Municipal Assembly authority to decide which land would be benefited and included in a sewer district. Trial findings described topography near the park, connections that may have drained into the sewer, and the absence of proof who made those connections or when. The state courts found no evidence of fraud, oppression, or wholly unequal treatment from the omission, and the Supreme Court declined to overturn those factual findings.

Real world impact

As a result, the special tax assessment against the abutting property owners stands and the city may collect the sewer charges. The decision confirms that local officials have leeway to draw sewer districts and that courts will interfere only when there is clear proof of arbitrary, oppressive, or unequal action. Property owners challenging similar assessments must show affirmative proof of fraud or wholly unequal treatment to prevail.