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Hunter v. City of Pittsburgh
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| Hunter v. City of Pittsburgh | |
| Reference: 207 U.S. 161 | |
| Term: 1907 | |
| Important Dates | |
| Argued: October 25-28, 1907 Decided: November 18, 1907 | |
| Outcome | |
| Pennsylvania Supreme Court affirmed | |
| Majority | |
| William Henry Moody • Melville Fuller • John Harlan I • David Josiah Brewer • Edward Douglass White • Rufus Wheeler Peckham • Joseph McKenna • Oliver Wendell Holmes • William Rufus Day | |
Hunter v. City of Pittsburgh is a case decided on November 18, 1907, by the United States Supreme Court holding that states have sovereignty over their local governments. The case concerned whether the consolidation of two cities impairs the obligation of a contract that exists between a city and its taxpaying citizens. The Supreme Court affirmed the ruling of the Pennsylvania Supreme Court.[1][2][3]
Why it matters: The Supreme Court's decision in this case established that states have sovereignty over their local governments. To read more about the impact of Hunter v. City of Pittsburgh click here.
Background
The city of Pittsburgh petitioned for the union of Pittsburgh and Allegheny in 1906, pursuant to a Pennsylvania law permitting the consolidation of contiguous cities by a majority vote. The city of Allegheny filed exceptions to the petition and argued that it would be unconstitutional to subject the citizens of Allegheny to higher taxes as a result of consolidation. A lower court dismissed the exceptions and ordered the cities to hold an election. A majority of voters voted in favor of consolidating the two cities, however, a majority of voters in Allegheny voted against consolidation.
Plaintiffs from Allegheny filed a writ of error to the Pennsylvania Superior Court, arguing that the act of consolidation violated a contract between the municipality and its taxpaying citizens that states they can only be taxed for uses of that corporation and cannot be taxed at a higher rate for the enlarged municipality. The Pennsylvania Superior Court affirmed the consolidation. A writ of error was then filed to the Pennsylvania Supreme Court and the consolidation was affirmed. The plaintiffs appealed the case to the Supreme Court for review of the decision and the decision of the Pennsylvania Supreme Court was affirmed.[2][3]
Oral argument
Oral argument was held between October 25, 1907, and October 28, 1907. The case was decided on November 18, 1907.[1]
Decision
The Supreme Court decided unanimously to affirm the decision of the Pennsylvania Supreme Court. Justice William Henry Moody delivered the opinion of the court.[1]
Opinions
Opinion of the court
Justice William Henry Moody, writing for the court, argued that several assignments within the writ of error were outside the jurisdiction of the Supreme Court and were for the consideration of the state legislative power.
| “ | We have nothing to do with the policy, wisdom, justice, or fairness of the act under consideration; those questions are for the consideration of those to whom the state has entrusted its legislative power, and their determination of them is not subject to review or criticism by this Court. We have nothing to do with the interpretation of the constitution of the state and the conformity of the enactment of the assembly to that constitution; those questions are for the consideration of the courts of the state, and their decision of them is final. [4] | ” |
| —William Henry Moody, majority opinion in Hunter v. City of Pittsburgh[1] | ||
Moody addressed two remaining claims proposed in the writ of error. The first claim posited that the act of consolidation impaired the obligation of a contract between the city of Allegheny and its citizens. Moody established that the city of Allegheny had not expressly established such a contract and therefore it had no authority to guide the claim.
| “ | This assignment does not rest upon the theory that the charter of the city is a contract with the state, a proposition frequently denied by this and other courts. It rests upon the novel proposition that there is a contract between the citizens and taxpayers of a municipal corporation and the corporation itself that the citizens and taxpayers shall be taxed only for the uses of that corporation, and shall not be taxed for the uses of any like corporation with which it may be consolidated. It is not said that the City of Allegheny expressly made any such extraordinary contract, but only that the contract arises out of the relation of the parties to each other. It is difficult to deal with a proposition of this kind except by saying that it is not true. No authority or reason in support of it has been offered to us, and it is utterly inconsistent with the nature of municipal corporations, the purposes for which they are created, and the relation they bear to those who dwell and own property within their limits. This assignment of error is overruled. [4] | ” |
| —William Henry Moody, majority opinion in Hunter v. City of Pittsburgh[1] | ||
The second claim contended that consolidation denied citizens of Allegheny their property without due process of law. Moody rejected this claim, arguing that states have the authority to make decisions regarding a municipality with or without the consent of their citizens.
| “ | Municipal corporations are political subdivisions of the state, created as convenient agencies for exercising such of the governmental powers of the state as may be entrusted to them. For the purpose of executing these powers properly and efficiently, they usually are given the power to acquire, hold, and manage personal and real property. The number, nature, and duration of the powers conferred upon these corporations and the territory over which they shall be exercised rests in the absolute discretion of the state. Neither their charters, nor any law conferring governmental powers, or vesting in them property to be used for governmental purposes, or authorizing them to hold or manage such property, or exempting them from taxation upon it constitutes a contract with the state within the meaning of the federal Constitution. The state, therefore, at its pleasure, may modify or withdraw all such powers, may take without compensation such property, hold it itself, or vest it in other agencies, expand or contract the territorial area, unite the whole or a part of it with another municipality, repeal the charter and destroy the corporation. All this may be done, conditionally or unconditionally, with or without the consent of the citizens, or even against their protest. In all these respects, the state is supreme, and its legislative body, conforming its action to the state constitution, may do as it will, unrestrained by any provision of the Constitution of the United States. [4] | ” |
| —William Henry Moody, majority opinion in Hunter v. City of Pittsburgh[1] | ||
Impact
| Federalism |
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| •Key terms • Court cases •Major arguments • State responses to federal mandates • Federalism by the numbers • Index of articles about federalism |
- See also: State sovereignty
Hunter v. City of Pittsburgh established that states have sovereignty over their local governments. The decision of the case confirmed, as established by the U.S. Constitution, that states are granted supreme authority over the municipalities in their jurisdiction and that state legislative bodies have the authority to make decisions or modifications that directly impact the citizens of a municipality within its jurisdiction, with or without the consent of its citizens. The majority opinion for the case states that:
| “ | The state, therefore, at its pleasure, may modify or withdraw all such powers, may take without compensation such property, hold it itself, or vest it in other agencies, expand or contract the territorial area, unite the whole or a part of it with another municipality, repeal the charter and destroy the corporation. All this may be done, conditionally or unconditionally, with or without the consent of the citizens, or even against their protest. In all these respects, the state is supreme, and its legislative body, conforming its action to the state constitution, may do as it will, unrestrained by any provision of the Constitution of the United States. [4] | ” |
| —William Henry Moody, majority opinion in Hunter v. City of Pittsburgh[1] | ||
See also
- The Fuller Court
- Supreme Court of the United States
- History of the Supreme Court
- Federalism
- State sovereignty
External links
- Full text of case syllabus and opinions (Justia)
- Supreme Court of the United States
- Search Google News for this topic
Footnotes
- ↑ 1.0 1.1 1.2 1.3 1.4 1.5 1.6 Justia, "Hunter v. City of Pittsburgh," accessed June 8, 2022
- ↑ 2.0 2.1 LexisNexis, "Hunter v. Pittsburgh - 207 U.S. 161, 28 S. Ct. 40 (1907)," accessed June 8, 2022
- ↑ 3.0 3.1 FindLaw, "Hunter v. City of Pittsburgh," accessed June 8, 2022
- ↑ 4.0 4.1 4.2 4.3 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
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