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Tyler v. Hennepin County, Minnesota

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Supreme Court of the United States
Tyler v. Hennepin County, Minnesota
Term: 2022
Important Dates
Argued: April 26, 2023
Decided: May 25, 2023
Outcome
reversed
Vote
9-0
Majority
Chief Justice John Roberts • Clarence Thomas • Samuel Alito • Sonia Sotomayor • Elena Kagan • Neil Gorsuch • Brett Kavanaugh • Amy Coney Barrett • Ketanji Brown Jackson
Concurring
Neil Gorsuch • Ketanji Brown Jackson

Tyler v. Hennepin County, Minnesota is a case that was decided by the Supreme Court of the United States on May 25, 2023, during the court's October 2022-2023 term. The case was argued before the Supreme Court of the United States on April 26, 2023. In a 9-0 opinion, the Court reversed the judgment of the United States Court of Appeals for the Eighth Circuit, holding that Tyler does plausibly allege that Hennepin County violated the Takings Clause of the Fifth Amendment by failing to give her the excess $25,000 that they received from selling her condo. Chief Justice John Roberts delivered the opinion.[1]

HIGHLIGHTS
  • The questions presented: “1. Whether taking and selling a home to satisfy a debt to the government, and keeping the surplus value as a windfall, violates the Takings Clause? 2. Whether the forfeiture of property worth far more than needed to satisfy a debt plus, interest, penalties, and costs, is a fine within the meaning of the Eighth Amendment?”[2]
  • The outcome: In a 9-0 opinion, the Supreme Court reversed the judgment of the United States Court of Appeals for the Eighth Circuit, holding that Tyler does plausibly allege that Hennepin County violated the Takings Clause of the Fifth Amendment by failing to give her the excess $25,000 that they received from selling her condo.[1]


    • The case came on a writ of certiorari to the United States Court of Appeals for the Eighth Circuit. To review the lower court's opinion, click here.

    Timeline

    The following timeline details key events in this case:

    Background

    Geraldine Tyler accumulated $15,000 in unpaid property taxes on a condominium that she owned in Minneapolis. To collect the debt, Hennepin County placed her home in foreclosure and sold it for $40,000. Tyler filed a suit against the county in the United States District Court for the District of Minnesota, arguing that Hennepin County violated the Takings Clause of the Fifth Amendment by selling her $40,000 condo to settle a $15,000 debt and not paying her the $25,000 surplus. The district court ruled against Tyler due to failure to state a claim. Tyler appealed to the United States Court of Appeals for the Eighth Circuit, which affirmed the district court's decision.[3][4]

    Questions presented

    The petitioner presented the following questions to the court:[2]

    Questions presented:
    “ 1. Whether taking and selling a home to satisfy a debt to the government, and keeping the surplus value as a windfall, violates the Takings Clause? 2. Whether the forfeiture of property worth far more than needed to satisfy a debt plus, interest, penalties, and costs, is a fine within the meaning of the Eighth Amendment?

    [5]

    		”

    Oral argument

    Audio

    Audio of oral argument:[6]




    Transcript

    Transcript of oral argument:[7]

    Outcome

    In a 9-0 opinion, the Supreme Court reversed the judgment of the United States Court of Appeals for the Eighth Circuit, holding that Tyler does plausibly allege that Hennepin County violated the Takings Clause of the Fifth Amendment by failing to give her the excess $25,000 that they received from selling her condo. Chief Justice John Roberts delivered the opinion of the court.[1]

    Opinion

    In the court's majority opinion, Chief Justice John Roberts wrote:[1]

    “ The Takings Clause “was designed to bar Government from forcing some people alone to bear public burdens which, in all fairness and justice, should be borne by the public as a whole.” Armstrong, 364 U. S., at 49. A taxpayer who loses her $40,000 house to the State to fulfill a $15,000 tax debt has made a far greater contribution to the public fisc than she owed. The taxpayer must render unto Caesar what is Caesar’s, but no more. Because we find that Tyler has plausibly alleged a taking under the Fifth Amendment, and she agrees that relief under “the Takings Clause would fully remedy [her] harm,” we need not decide whether she has also alleged an excessive fine under the Eighth Amendment. Tr. of Oral Arg. 27. The judgment of the Court of Appeals for the Eighth Circuit is reversed.

    [5]

    		”
    —Chief Justice John Roberts

    Concurring opinion

    Justice Neil Gorsuch filed a concurring opinion, joined by Justice Ketanji Brown Jackson. In his concurring opinion, Justice Gorsuch wrote:[1]

    “ The Court reverses the Eighth Circuit’s dismissal of Geraldine Tyler’s suit and holds that she has plausibly alleged a violation of the Fifth Amendment’s Takings Clause. I agree. Given its Takings Clause holding, the Court understandably declines to pass on the question whether the Eighth Circuit committed a further error when it dismissed Ms. Tyler’s claim under the Eighth Amendment’s Excessive Fines Clause. Ante, at 14. But even a cursory review of the District Court’s excessive-fines analysis—which the Eighth Circuit adopted as “well-reasoned,” 26 F. 4th 789, 794 (2022)—reveals that it too contains mistakes future lower courts should not be quick to emulate.[5] ”
    —Justice Neil Gorsuch

    Text of the opinion

    Read the full opinion here.

    October term 2022-2023

    See also: Supreme Court cases, October term 2022-2023

    The Supreme Court began hearing cases for the term on October 3, 2022. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[8]


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 U.S. Supreme Court, "Tyler v. Hennepin County, Minnesota, et al.—On Petition for Writ of Certiorari to the United States Court of Appeals for the Eighth Circuit," accessed May 25, 2023
    2. ↑ 2.0 2.1 U.S. Supreme Court, "22-166 TYLER V. HENNEPIN COUNTY, MN," accessed January 24, 2022
    3. ↑ U.S. Supreme Court, "Geraldine Tyler, on behalf of herself and all others similarly situated, Petitioner, v. Hennepin County, and Mark V. Chapin, Auditor-Treasurer, in his official capacity, Respondents.—On Petition for Writ of Certiorari to the United States Court of Appeals for the Eighth Circuit," accessed January 13, 2023
    4. ↑ Oyez, "Tyler v. Hennepin County, Minnesota," accessed March 3, 2023
    5. ↑ 5.0 5.1 5.2 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    6. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued April 26, 2023
    7. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued April 26, 2023
    8. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed January 24, 2022
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