Rowley v. Chicago & Northwestern Ry. Co., 293 U.S. 102 (1934)

Contents:
Author: U.S. Supreme Court

Show Summary

Rowley v. Chicago & Northwestern Ry. Co., 293 U.S. 102 (1934)

Please note: this case begins in mid-page. It therefore shares a citation with the last page of the previous case. If you are attempting to follow a link to the last page of 293 U.S. 96, click here.

Rowley v. Chicago & Northwestern Railway Co.


No. 9


Argued October 10, 1934
Decided November 5, 1934
293 U.S. 102

CERTIORARI TO THE CIRCUIT COURT OF APPEALS
FOR THE TENTH CIRCUIT

Syllabus

1. The Court is reluctant to place constructions upon state statutes of doubtful meaning, or to decide other questions of state law as to which there may be substantial controversy, in advance of decision by the state courts of last resort. P. 104.

2. The ascertainment of the value of a railway system is not a matter of arithmetical calculation, and is not governed by any fixed and definite rule. Facts of great variety and number, estimates that are exact and those that are approximations, forecasts based on probabilities and contingencies, have bearing and properly may be taken into account to guide judgment in determining what is the money equivalent -- the actual value -- of the property. P. 109.

3. An apportionment of system value of a railroad for taxation in one of several States traversed by its lines cannot be adjudged arbitrary merely because the mileage basis was used, although the average value per mile in that State was much less than for the system as a whole, where the mileage ratio was applied not singly, but combined with others, such as the ratios of the traffic units, use of rolling stock, and average of gross and net operating revenue in that State to the system totals, where the computation was tested by other criteria, such as the relations between cost of reproduction less depreciation of the local property and system value and between operating net revenues derived from that property and those earned by the system, and where there is nothing to show that the assessment was excessive. P. 110.

4. Overvaluation by state tax officials resulting from error of judgment will not support a claim of discrimination. There must be something that amounts to an intention, or the equivalent of fraudulent purpose, to disregard the fundamental principle of uniformity. P. 111.

5. Upon finding in an injunction suit that a state tax violates the equal protection clause of the Fourteenth Amendment because of discrimination in assessment, the federal court should leave the State free to reassess; it is without jurisdiction to fix the base and amount of the tax that may be lawfully exacted . P. 112.

68 F.2d 527 reversed.

Certiorari, 292 U.S. 618, to review the affirmance of a decree of the District Court holding state taxes on the Railway Company’s property in Wyoming arbitrary and excessive and enjoining collection upon the condition that the Company pay taxes on a reduced valuation made by the court.

Contents:

Related Resources

None available for this document.

Download Options


Title: Rowley v. Chicago & Northwestern Ry. Co., 293 U.S. 102 (1934)

Select an option:

*Note: A download may not start for up to 60 seconds.

Email Options


Title: Rowley v. Chicago & Northwestern Ry. Co., 293 U.S. 102 (1934)

Select an option:

Email addres:

*Note: It may take up to 60 seconds for for the email to be generated.

Chicago: U.S. Supreme Court, "Syllabus," Rowley v. Chicago & Northwestern Ry. Co., 293 U.S. 102 (1934) in 293 U.S. 102 293 U.S. 103. Original Sources, accessed August 8, 2022, http://www.originalsources.com/Document.aspx?DocID=4VECYJ21KKVZQYN.

MLA: U.S. Supreme Court. "Syllabus." Rowley v. Chicago & Northwestern Ry. Co., 293 U.S. 102 (1934), in 293 U.S. 102, page 293 U.S. 103. Original Sources. 8 Aug. 2022. http://www.originalsources.com/Document.aspx?DocID=4VECYJ21KKVZQYN.

Harvard: U.S. Supreme Court, 'Syllabus' in Rowley v. Chicago & Northwestern Ry. Co., 293 U.S. 102 (1934). cited in 1934, 293 U.S. 102, pp.293 U.S. 103. Original Sources, retrieved 8 August 2022, from http://www.originalsources.com/Document.aspx?DocID=4VECYJ21KKVZQYN.