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Rutherford v. Geddes was a United States Supreme Court case that dealt with the issue of whether a state could pass a law that allowed a private individual to collect debts owed to the state. The case was brought by the state of New York, which had passed a law allowing a private individual, Geddes, to collect debts owed to the state. The state argued that the law was constitutional, while Rutherford, the debtor, argued that it was unconstitutional. The Supreme Court ultimately sided with Rutherford, ruling that the law was unconstitutional. The Court held that the law violated the Due Process Clause of the Fourteenth Amendment, which states that no state shall “deprive any person of life, liberty, or property, without due process of law.” The Court reasoned that the law allowed Geddes to collect debts without any judicial oversight, which violated the Due Process Clause. The Court’s decision in Rutherford v. Geddes established an important precedent that states cannot pass laws that allow private individuals to collect debts owed to the state without judicial oversight. This decision has been cited in numerous subsequent cases, and it remains an important part of constitutional law today.
In the case of Rutherford v. Geddes, the Supreme Court was asked to decide whether a state law that allowed private individuals to purchase delinquent tax liens at public auctions violated the Constitution's Contract Clause. The majority opinion held that it did not violate this clause because states have broad authority over taxation and collection of taxes. Justice Field dissented from this decision, arguing that while states do indeed possess such powers, they must still abide by constitutional limits on their exercise of those powers. He argued that allowing private individuals to buy up delinquent tax liens at public auctions constituted an unconstitutional taking without just compensation in violation of the Fifth Amendment as well as an impairment of contracts in violation of Article I Section 10 Clause 1 (the Contract Clause). Furthermore, he argued that these laws were arbitrary and oppressive since they gave no consideration for individual circumstances or ability to pay when determining who should be subject to them; thus depriving people due process rights under the Fourteenth Amendment.