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Bissell v. Spring Valley Township

• 1887 • 124 U.S. 225 • Waite Court
Bissell v. Spring Valley Township is a United States Supreme Court case that dealt with the issue of whether a township had the authority to levy taxes on a railroad. The plaintiff, Bissell, was the owner of a railroad that ran through Spring Valley Township. The township had passed a tax ordinance that imposed a tax on the railroad, which Bissell argued was unconstitutional. The Supreme Court held that the township did not have the authority to levy taxes on the railroad. The Court reasoned...Open Case
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Chief Waite Court
Term: 1887
Docket: 1261
124 U.S. 225
8 S. Ct. 495
31 L. Ed. 411
1888 U.S. LEXIS 1856

Bissell v. Spring Valley Township

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Opinion Summary
AI Abstract

Bissell v. Spring Valley Township is a United States Supreme Court case that dealt with the issue of whether a township had the authority to levy taxes on a railroad. The plaintiff, Bissell, was the owner of a railroad that ran through Spring Valley Township. The township had passed a tax ordinance that imposed a tax on the railroad, which Bissell argued was unconstitutional. The Supreme Court held that the township did not have the authority to levy taxes on the railroad. The Court reasoned that the power to tax railroads was reserved to the state, and that the township had exceeded its authority in attempting to tax the railroad. The Court also noted that the tax ordinance was not a valid exercise of the township's police power, as it did not serve a legitimate public purpose. The Court's decision in Bissell v. Spring Valley Township established that local governments do not have the authority to tax railroads, and that such taxes must be imposed by the state. This decision has been cited in numerous subsequent cases involving the taxation of railroads.

Dissent Summary
AI Abstract

Justice Field delivered the dissenting opinion in BISSELL v. SPRING VALLEY TOWNSHIP, arguing that the majority's decision was contrary to established precedent and would have a detrimental effect on municipal corporations. He argued that Spring Valley Township had acted within its authority when it issued bonds for public improvements, as this power is granted by state law and has been upheld by numerous court decisions. Furthermore, he noted that if municipalities were not allowed to issue such bonds without approval from all of their citizens then they would be unable to make any improvements at all since it is impossible for them to obtain unanimous consent from every citizen. Finally, Justice Field stated that allowing individual taxpayers like Bissell to challenge these bond issues could lead to chaos and confusion in local government affairs as each taxpayer could potentially bring suit against any action taken by a municipality which affects his or her taxes.

Opinion written by Justice SJField
Decided: Jan 09, 1888
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