Tyler v. Hennepin County, Minnesota
United States Supreme Court
598 U.S. 631, 143 S.Ct. 1369 (2023)
- Written by Jamie Milne, JD
Facts
Geraldine Tyler (plaintiff) owned a condominium in Hennepin County, Minnesota (the county) (defendant). After Tyler’s family moved her into a senior community, nobody paid the condominium’s annual property taxes. Eventually, the county seized and sold the condominium to satisfy Tyler’s tax debt. The county sold the condominium for $40,000. Because Tyler’s debt was only $15,000, there was a $25,000 surplus in sale proceeds. Per Minnesota law, the county retained the surplus. Tyler sued the county, arguing, among other things, that retaining the surplus violated the Fifth Amendment’s Takings Clause. The district court dismissed the suit for failure to state a viable claim. The court of appeals affirmed. The court reasoned that under Minnesota law, surplus proceeds from a tax sale belonged to the government and Tyler therefore did not have a property interest in the surplus. Because Tyler did not have a property interest, the county’s retention of the surplus did not constitute a taking. The United States Supreme Court granted certiorari.
Rule of Law
Issue
Holding and Reasoning (Roberts, C.J.)
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