Fort Leavenworth R.R. Co. v. Lowe
United States Supreme Court
114 U.S. 525 (1885)
The United States acquired land constituting the Fort Leavenworth Military Reservation (reservation) in 1803, by cession from France. The United States had exclusive jurisdiction over the land until the admission of Kansas into the Union in 1861. Because Congress failed to stipulate its retention of exclusive jurisdiction over the reservation, the United States retained only the rights of an ordinary proprietor, with the exception of the reservation’s use for military purposes. To resolve the jurisdictional defect, Kansas passed an act of cession that gave the United States exclusive jurisdiction over the reservation. However, the act contained a savings clause that gave Kansas the right to tax railroads, bridges, and other corporations located on the reservation. Kansas subsequently levied a property tax on the Fort Leavenworth Railroad Company (plaintiff), which owned a railroad located within the reservation. The company paid the tax under protest, then filed suit on the basis that the savings clause was inconsistent with the exclusive jurisdiction granted to the United States by the act of cession.
Rule of Law
Holding and Reasoning (Field, J.)
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