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The Widow And Heirs Of Benjamin Poydras De La Lande, Plaintiffs In Error, v. The Treasurer Of The State Of Louisiana

1855 • 59 U.S. 192 • Taney Court
In this case, the widow and heirs of Benjamin Poydras de la Lande brought a suit against the Treasurer of Louisiana. The plaintiffs argued that they were entitled to compensation for land taken by the state in 1845 under an act passed by the legislature. The court found that while it was true that no specific provision had been made for payment at the time, it could not be denied that there was an implied obligation on behalf of Louisiana to pay just compensation for taking private property....Open Case
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Oh No!
Chief Taney Court
Term: 1855
59 U.S. 192
15 L. Ed. 350
1855 U.S. LEXIS 684
Argued: Jan 23, 1856

The Widow And Heirs Of Benjamin Poydras De La Lande, Plaintiffs In Error, v. The Treasurer Of The State Of Louisiana

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Opinion Summary
AI Abstract

In this case, the widow and heirs of Benjamin Poydras de la Lande brought a suit against the Treasurer of Louisiana. The plaintiffs argued that they were entitled to compensation for land taken by the state in 1845 under an act passed by the legislature. The court found that while it was true that no specific provision had been made for payment at the time, it could not be denied that there was an implied obligation on behalf of Louisiana to pay just compensation for taking private property. Furthermore, since more than ten years had elapsed between when their land was taken and when they filed their claim with the state treasurer, any right to recover damages from them had expired due to laches or delay in bringing suit. As such, judgment was entered in favor of defendants and plaintiffs' claims dismissed without prejudice as barred by laches.

Dissent Summary
AI Abstract

In this case, the Supreme Court was asked to decide whether the state of Louisiana had a right to tax property that belonged to Benjamin Poydras de la Lande. The majority opinion held that it did have such a right and dismissed the plaintiffs' claims. However, Justice Curtis dissented from this ruling and argued that under Article I Section 10 of the United States Constitution, which prohibits states from passing any law impairing contracts or obligations, Louisiana's taxation laws were unconstitutional as they impaired an obligation created by contract between two parties in 1803. He further argued that even if there was no explicit contract between these two parties at issue here, there still existed an implied agreement based on principles of equity and justice which could not be violated by subsequent legislation passed by Louisiana. Thus he concluded that since Louisana's taxation laws interfered with either an express or implied contractual obligation existing prior to their passage they should be declared void as being in violation of Article I Section 10 of the United States Constitution.

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