95 Year old Minnesota Woman wins at Supreme Court
After an uncharacteristically fast track (at least for this Court Term), the Supreme Court has unanimously decided that Hennepin County violated the Fifth Amendment’s takings clause when it seized and sold Geraldine Tyler’s condo, keeping the surplus from the sale. See previous post on this case.
The Takings Clause of the Fifth Amendment to the United States Constitution states that “private property [shall not] be taken for public use, without just compensation.” This clause has been interpreted by the courts to mean that the government cannot take private property without providing just compensation to the property owner. In Kelo v. City of New London (2005) the Supreme Court held that the government’s taking of private property to sell for private development qualified as a “public use” in the context of eminent domain. Tyler’s case is unique in that Tyler’s property was seized to pay a delinquent debt, under some rather interesting circumstances.
To recap, in 2016, 94-year-old Geraldine Tyler’s condo was sold at auction by Hennepin County due to several years of unpaid property taxes. The sale yielded $40,000, of which the county kept not only the $15,000 in taxes, penalties, and costs that Tyler owed but also the remaining $25,000. This action was challenged by Tyler, leading to the Supreme Court case Tyler v. Hennepin County.
The county argued that Tyler was not actually harmed by the sale of her condo, suggesting she may have had a mortgage for $49,000 on the property, as well as a $12,000 lien for unpaid homeowners’ association fees. However, the justices dismissed these claims as speculation, noting that the county had never actually provided evidence of either the mortgage or the lien. Chief Justice John Roberts stated, “Tyler still plausibly alleges a financial harm: The County has kept $25,000 that belongs to her.”
The court’s ruling emphasized that property rights cannot be easily manipulated. Roberts observed that even Minnesota itself recognizes that in other contexts, a property owner is entitled to the surplus in excess of her debt. By keeping the $25,000, the county “effected a ‘classic taking in which the government directly appropriates private property for its own use.’”
This ruling is a significant victory for property rights, affirming that they are fundamental and do not depend solely on state law. It makes clear that home equity theft is not only unjust but unconstitutional.
While the court did not resolve Tyler’s argument that the county’s actions also violated the Eighth Amendment’s ban on excessive fines, Justice Neil Gorsuch, joined by Justice Ketanji Brown Jackson, suggested in a concurring opinion that Tyler would have prevailed on this ground as well.
This case serves as a reminder of the importance of property rights and the role of the Supreme Court in upholding these rights. It also raises questions about the practices of counties and states in handling property seizures and sales, and whether reforms are needed to ensure that property owners are treated fairly and constitutionally.\
Chief Robert’s Opinion:22-166_8n59