Tyler v. Hennepin County (22-166)

argument 22-166

Tyler v. Hennepin County

Supreme Court of the United States 1h 40m 8 speakers 8 chapters transcribed 8 days ago official recording ↗

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What constitutional issue does the case of Tyler v. Hennepin County raise?

John G. Roberts 0:00

We'll hear argument this morning in Case 22166, Tyler v. Hennepin County, Minnesota. Ms. Martin.

Unknown 0:08

Mr. Chief Justice, and may it please the Court. When the government takes property to satisfy a debt and takes more than what is owed, it has a constitutional duty to return or pay for the excess. Here, Geraldine Tyler owed $15,000, which included nearly $13,000 in penalties, interest, and related costs. To satisfy that debt, Hennepin County took Ms. Tyler's former home, which was worth much more than that, and later sold it for $40,000. The county kept all $40,000 for public uses. By taking absolute title to Ms. Tyler's property, including the value that exceeded the debt, the county has taken private property without just compensation. The county could have collected the debt without violating the Constitution by following the traditional common law rule still followed in most states and still followed in Minnesota in nearly every other debt collection circumstance.

Unknown 1:08

Under that rule, the county should have taken the property, sold it, paid the debts from the proceeds, and refunded the remainder to Ms. Tyler. Instead, the county took everything. The county apparently does not dispute that Ms. Tyler had a property interest in her former home or in its value. Instead, it asserts that the government may redefine private property by statute. The consequence of that would be an unlimited power to define away private property and to confiscate it to pay debts no matter how valuable the property or how small the debt. But this court's takings decisions... In hundreds of years of common law, Minnesota's own treatment of debts and nearly every other debt collection circumstance confirmed that the county has taken private property for which it must pay just compensation.

Unknown 2:01

If not remedied with just compensation, then the confiscation acts as a fine, punishing Ms. Tyler for the public offense of failing to timely pay her property taxes. The confiscation of a property should therefore be subject to scrutiny under the excessive fines clause because it goes well beyond compensating the government for any loss. This Court has repeatedly held that an economic sanction that serves in part to punish is a fine within the meaning of the Eighth Amendment. I welcome the Court's questions.

Clarence Thomas 2:30

If there was no differential in the... If there was no surplus equity, would there be a taking?

Unknown 2:39

Yes, Your Honor. Well... Are you asking if the property was worth less than what she owed the

Clarence Thomas 2:45

county? Or worth the $15,000?

Unknown 2:50

There would be a taking, but just compensation would be paid at the time of the taking of absolute title by forgiving the debt.

Clarence Thomas 2:58

So normally we say that a taking claim accrues when the government takes the property. And how would we know that? what the value of the property is at the time of the taking,

Unknown 3:14

when the

Clarence Thomas 3:15

sale doesn't occur until years later.

Unknown 3:17

So in this particular case, it's true the sale was more than a year later, but trial courts handle valuation analyses all the time, and so they would just use the same analysis applicable in any other circumstance, and they could consider the auction price as probably the best proxy for what the property was worth.

Clarence Thomas 3:39

Normally, we only see these takings claims when you have eminent domain or something that's traditional. So why should we extend it to areas such as forfeiture or taxation and the area property taxes?

Unknown 3:55

Because the right that we're asserting here is a deeply rooted right that a debt collector may not take more than what's owed. The way that debt collectors ordinarily get around that is by taking the property subject to that traditional common law rule. Blackstone called it an implied contract at law, that they would take the property, sell it in a fair arm's length transaction, usually by auction, and then return any excess after they pay off the debts.

John G. Roberts 4:22

Well, it's a deeply rooted right that's traditionally defined by state law. You know, in some places, your property line goes up to the high water mark. In other states, it goes to the low water mark.