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Stevenson v. Barbour

• 1890 • 140 U.S. 48 • Fuller Court
In Stevenson v. Barbour (1890), the U.S Supreme Court was asked to determine whether a Kentucky law that allowed for the confiscation and sale of property owned by non-residents, who did not pay taxes on said property, violated the Fourteenth Amendment's Equal Protection Clause. The plaintiff in this case was a resident of Ohio who owned land in Kentucky but had failed to pay his taxes there. As a result, his land was seized and sold by local authorities under state law provisions allowing such...Open Case
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Chief Fuller Court
Term: 1890
Docket: 304
140 U.S. 48
11 S. Ct. 690
35 L. Ed. 338
1891 U.S. LEXIS 2429
Argued: Apr 14, 1891

Stevenson v. Barbour

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Opinion Summary
AI Abstract

In Stevenson v. Barbour (1890), the U.S Supreme Court was asked to determine whether a Kentucky law that allowed for the confiscation and sale of property owned by non-residents, who did not pay taxes on said property, violated the Fourteenth Amendment's Equal Protection Clause. The plaintiff in this case was a resident of Ohio who owned land in Kentucky but had failed to pay his taxes there. As a result, his land was seized and sold by local authorities under state law provisions allowing such actions against non-resident tax delinquents. The court ruled in favor of Barbour, upholding the constitutionality of Kentucky's laws regarding taxation and seizure of properties belonging to out-of-state residents. It held that these laws did not violate equal protection rights as they applied equally to both residents and non-residents alike - anyone failing to pay their due taxes would face similar consequences regardless of where they resided. This ruling affirmed states' rights over matters concerning taxation within their jurisdictions while also emphasizing individual responsibility towards fulfilling tax obligations irrespective of residency status.

Dissent Summary
AI Abstract

In the dissenting opinion for Stevenson v. Barbour, Justice Lamar argued that the majority's decision to uphold a Kentucky law prohibiting non-residents from suing in state courts was unconstitutional. He believed it violated Article IV of the Constitution which guarantees citizens of each state all privileges and immunities of citizens in other states. This includes access to courts for legal redress. The justice contended that this ruling allowed states to discriminate against out-of-state residents by denying them equal protection under the law, thus contradicting principles established by previous Supreme Court decisions such as Corfield v Coryell (1823) and Ward v Maryland (1870). Furthermore, he asserted that if every state enacted similar laws, interstate commerce would be severely hindered as businesses could not reliably enforce contracts or resolve disputes across borders.

Opinion written by Justice
Decided: Apr 20, 1891
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