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Geraldine Tyler v. Hennepin County, Minnesota, et al.

Paid petition · United States Court of Appeals for the Eighth Circuit, No. 20-3730 · judgment February 16, 2022


Decided · May 25, 2023
Pre-decision estimate: 10% cert probability (95% interval 6%–16%)

Before the decision, about 2.4× the 4.1% base rate. The model weighted this up for counsel with five or more prior petitions here, a circuit split argued in the petition, and an Eighth Circuit decision below.

Questions presented

Hennepin County confiscated 93-year-old Geraldine Tyler's former home as payment for approximately $15,000 in property taxes, penalties, interest, and costs. The County sold the home for $40,000, and, consistent with a Minnesota forfeiture statute, kept all proceeds, including the $25,000 that exceeded Tyler's debt as a windfall for the public. In all states, municipalities may take real property and sell it to collect payment for property tax debts. Most states allow the government to keep only as much as it is owed; any surplus proceeds after collecting the debt belong to the former owner. But in Minnesota and a dozen other states, local governments take absolute title, extinguishing the owner's equity in exchange only for cancelling a smaller tax debt, code enforcement fine, or debt to government agencies. The questions presented are:

  1. Whether taking and selling a home to satisfy a debt to the government, and keeping the surplus value as a windfall, violates the Takings Clause?

  2. Whether the forfeiture of property worth far more than needed to satisfy a debt plus, interest, penalties, and costs, is a fine within the meaning of the Eighth Amendment?

Counsel of record

For petitioner
Christina Marie Martin
Pacific Legal Foundation

For respondent
Rebecca Lee Stark Holschuh
Hennepin County Attorney's Office

Case

Conference history
Distributed for 3 conferences

Amicus briefs
8 cert-stage · 36 merits
(26 supporting pet./neither, 10 respondent)

Argument & decision

Argued April 26, 2023 — Christina M. Martin · Erica L. Ross · Neal K. Katyal. Audio and transcript

Decided May 25, 2023. Opinion by Roberts, C.J..

Proceedings

  1. Jun 26 2023
    Judgment issued.
  2. Jun 14 2023
    Record returned to the U.S.C.A.-8th Circuit (1 box).
  3. May 25 2023
    Judgment REVERSED. Roberts, C. J., delivered the opinion for a unanimous Court. Gorsuch, J., filed a concurring opinion, in which Jackson, J., joined.
  4. Apr 26 2023
    Argued. For petitioner: Christina M. Martin, Palm Beach Gardens, Fla. For United States, as amicus curiae: Erica L. Ross, Assistant to the Solicitor General, Department of Justice, Washington, D. C. For respondents: Neal K. Katyal, Washington, D. C
  5. Apr 14 2023
    Motion of the Solicitor General for leave to participate in oral argument as amicus curiae and for divided argument GRANTED IN PART, a total of 65 minutes is allotted, and the time is divided as follows: 25 minutes for petitioner, 10 minutes for the Solicitor General, and 30 minutes for respondents.
  6. Apr 12 2023
    Reply of petitioner Geraldine Tyler filed. (Distributed)
  7. Apr 05 2023
    Brief amicus curiae of Wisconsin Counties Association filed. (Distributed)
  8. Apr 05 2023
    Brief amicus curiae of Oakland County filed. (Distributed)
  9. Apr 05 2023
    Brief amici curiae of County Treasurers Association of Ohio, et al. filed. (Distributed)
  10. Apr 05 2023
    Brief amici curiae of Local Government Legal Center, National Association of Counties, National League of Cities, International Municipal Lawyers Association, and Government Finance Officers Association filed. (Distributed)
  11. Apr 05 2023
    Brief amici curiae of Michigan Association of Counties, et al. filed. (Distributed)
  12. Apr 05 2023
    Brief amici curiae of Association of Minnesota Counties, et al. filed. (Distributed)
  13. Apr 04 2023
    Brief amici curiae of Minnesota, et al. filed. (Distributed)
  14. Apr 04 2023
    Brief amicus curiae of James J. Kelly filed. (Distributed)
  15. Apr 04 2023
    Brief amicus curiae of Frank S. Alexander filed. (Distributed)
  16. Mar 31 2023
    Brief amici curiae of National Tax Lien Association, the Arizona County Treasurers Association, and the Tax Collectors & Treasurers Association of New Jersey filed. (Distributed)
  17. Mar 31 2023
    Motion of the Solicitor General for leave to participate in oral argument as amicus curiae and for divided argument filed.
  18. Mar 31 2023
    Response of respondent in support of proposed lodging of Minnesota, et al. filed. (Distributed)
  19. Mar 30 2023
    Letter of petitioner in opposition to lodging proposal of Minnesota, et al. filed. (Distributed)
  20. Mar 29 2023
    Brief of respondents Hennepin County, et al. filed. (Distributed)
  21. Mar 29 2023
    Lodging proposal of amici curiae Minnesota, et al. filed. (Distributed)
  22. Mar 24 2023
    CIRCULATED
  23. Mar 10 2023
    The record for the U.S.D.C.-District of Minnesota is available on PACER.
  24. Mar 06 2023
    Brief amici curiae of National Taxpayers Union Foundation, et al. filed.
  25. Mar 06 2023
    Brief amici curiae of National Association of Realtors, Minnesota Realtors, and American Property Owners Alliance filed.
  26. Mar 06 2023
    Brief amici curiae of U.S. Representatives Tom Emmer, Pete Stauber, Michelle Fischbach, and Brad Finstad filed.
  27. Mar 06 2023
    Brief amicus curiae of Monica Toth filed.
  28. Mar 06 2023
    Brief amicus curiae of New England Legal Foundation filed.
  29. Mar 06 2023
    Brief amicus curiae of Chamber of Commerce of the United States of America filed.
  30. Mar 06 2023
    Brief amicus curiae of Constitutional Accountability Center filed.
  31. Mar 06 2023
    Brief amicus curiae of Professor Beth A. Colgan filed.
  32. Mar 06 2023
    Brief amicus curiae of PioneerLegal, LLC filed.
  33. Mar 06 2023
    Brief amicus curiae of Americans for Prosperity Foundation filed.
  34. Mar 06 2023
    Brief amicus curiae of United States supporting neither party filed.
  35. Mar 06 2023
    Brief amicus curiae of Francis J. Coffey, as Personal Representative of the Estates of Leona M. Warsowick, et al. filed.
  36. Mar 06 2023
    Brief amici curiae of AARP, AARP Foundation, and National Consumer Law Center filed.
  37. Mar 06 2023
    Brief amici curiae of States of Utah, Arkansas, Kansas, Kentucky, Louisiana, North Dakota, Texas, and West Virginia filed.
  38. Mar 06 2023
    Brief amici curiae of New Disabled South and Emory Law School Disabled Law Students Association filed.
  39. Mar 06 2023
    Brief amicus curiae of Public Citizen filed.
  40. Mar 06 2023
    Brief amici curiae of Buckeye Institute, et al. filed.
  41. Mar 06 2023
    Brief amicus curiae of National Legal Aid & Defender Association filed.
  42. Mar 03 2023
    Brief amici curiae of David C. Wilkes, et al. filed.
  43. Mar 03 2023
    Brief amicus curiae of Howard Jarvis Taxpayers Association filed.
  44. Mar 03 2023
    Brief amicus curiae of Atlantic Legal Foundation filed.
  45. Mar 02 2023
    Brief amici curiae of Cato Institute, et al. filed.
  46. Mar 02 2023
    Brief amicus curiae of Center for Constitutional Jurisprudence filed.
  47. Mar 02 2023
    Brief amicus curiae of Liberty Justice Center filed.
  48. Mar 02 2023
    Brief amicus curiae of Wisconsin Realtors Association filed.
  49. Mar 01 2023
    Brief amicus curiae of Ralph D. Clifford filed.
  50. Feb 27 2023
    Brief of petitioner Geraldine Tyler filed.
  51. Feb 27 2023
    Joint appendix filed. (Statement of costs filed)
  52. Feb 22 2023
    Rule 35.3 letter re substitution of party filed by respondents.
  53. Feb 21 2023
    Record received from the U.S.C.A.-8th Circuit (1 box). Record request also forwarded to District Court.
  54. Feb 08 2023
    Record requested from the U.S.C.A.-8th Circuit.
  55. Jan 31 2023
    SET FOR ARGUMENT on Wednesday, April 26, 2023.
  56. Jan 13 2023
    Petition GRANTED.
  57. Jan 09 2023
    DISTRIBUTED for Conference of 1/13/2023.
  58. Dec 21 2022
    DISTRIBUTED for Conference of 1/6/2023.
  59. Dec 19 2022
    Reply of petitioner Geraldine Tyler filed. (Distributed)
  60. Dec 05 2022
    Brief of Hennepin County, et al. in opposition not accepted for filing. (December 06, 2022)
  61. Dec 05 2022
    Brief of respondents Hennepin County, et al. in opposition filed.
  62. Oct 20 2022
    Brief amicus curiae of Cato Institute filed.
  63. Sep 23 2022
    Motion to extend the time to file a response is granted in part and the time is extended to and including December 5, 2022.
  64. Sep 22 2022
    Motion to extend the time to file a response from October 20, 2022 to December 19, 2022, submitted to The Clerk.
  65. Sep 22 2022
    Brief amici curiae of AARP and AARP Foundation filed.
  66. Sep 22 2022
    Brief amicus curiae of PioneerLegal, LLC filed.
  67. Sep 22 2022
    Brief amici curiae of Buckeye Institute and the Competitive Enterprise Institute filed.
  68. Sep 21 2022
    Brief amicus curiae of Howard Jarvis Taxpayers Association filed.
  69. Sep 21 2022
    Brief amicus curiae of Wisconsin Realtors Association filed.
  70. Sep 20 2022
    Response Requested. (Due October 20, 2022)
  71. Sep 20 2022
    Brief amici curiae of David C. Wilkes, et al. filed.
  72. Sep 16 2022
    Brief amicus curiae of National Taxpayers Union Foundation filed. (Distributed)
  73. Sep 14 2022
    DISTRIBUTED for Conference of 10/7/2022.
  74. Sep 09 2022
    Waiver of right of respondent Hennepin County, et al. to respond filed.
  75. Sep 09 2022
    Blanket Consent filed by Petitioner, Geraldine Tyler
  76. Aug 19 2022
    Petition for a writ of certiorari filed. (Response due September 22, 2022)
  77. Jul 28 2022
    Application (21A712) granted by Justice Kavanaugh extending the time to file until August 19, 2022.
  78. Jul 25 2022
    Application (21A712) to extend further the time from August 10, 2022 to August 19, 2022, submitted to Justice Kavanaugh.
  79. May 13 2022
    Application (21A712) granted by Justice Kavanaugh extending the time to file until August 10, 2022.
  80. May 09 2022
    Application (21A712) to extend the time to file a petition for a writ of certiorari from June 22, 2022 to August 10, 2022, submitted to Justice Kavanaugh.