St. Clair v. Yonkers Raceway, Inc.
New York Court of Appeals
13 N.Y.2d 72, 192 N.E.2d 15 (1963)
- Written by Tammy Boggs, JD
Facts
In New York, wagers at racetracks were placed and taxed in a certain manner under the Pari-Mutuel Revenue Law. The State of New York collected and spent the tax revenues. The legislature passed an amendment to the Pari-Mutuel Revenue Law, which reduced tax rates. As a result, the state collected less in taxes than before from racetrack wagering. Following the law’s amendment, Edward St. Clair (plaintiff) placed small wagers totaling $18 at Yonkers Raceway, Inc., and a few other racetracks (the racetracks) (defendants). St. Clair, on behalf of himself and other similarly situated taxpayers of New York, sued the racetracks, alleging that the amendment was unconstitutional, the state would have collected more taxes under the original law, and the difference in taxes caused by the invalid amendment should be paid to the state. The racetracks and the attorney general (defendant) moved to dismiss the complaint. The trial court dismissed the complaint on the basis that St. Clair lacked capacity to sue. St. Clair appealed.
Rule of Law
Issue
Holding and Reasoning (Burke, J.)
Dissent (Fuld, J.)
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