Holt v. Indiana Mfg. Co., 176 U.S. 68 (1900)

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Holt v. Indiana Manufacturing Company

No. 80

Argued December 19-20, 1899
Decided January 15, 1900
176 U.S. 68

APPEAL FROM THE CIRCUIT COURT OF THE UNITED

STATES FOR THE DISTRICT OF INDIANA

Syllabus

The reasons for refusing at October Term 1898, to dismiss this case on the ground that the appeal to this Court was not taken in time are the same as those set forth in Allen v. Southern Pacific Railroad, 173 U.S. 479.

The complaint of the Manufacturing Company that the assessment upon it of the taxes complained of was illegal, because in effect levied on patents or patent rights, did not involve the construction, or the validity, or the infringement of the patents referred to, or any other question under the patent laws, and was not therefore a suit arising under the patent laws, and the Circuit Court had no jurisdiction of it on that ground.

The provisions in Rev.Stat. § 629, clauses 9 and 16, § 563, and § 1979, brought forward from the Act of April 20, 1871, c. 22, refer to civil rights only, and are inapplicable here.

Following United States v. Sayward, 160 U.S. 493, and Fishback v. Western Union Tel. Co., 161 U.S. 96, the Court holds that the sum of $2,000 named in § 1 of the Act of March 3, 1887, c. 373, as corrected by the Act of August 13, 1888, c. 866, was jurisdictional, and following The Paquete Habana, 175 U.S. 677, it holds that this is not affected by the fact that the operation of the Act of March 3, 1891, c. 517, was to do away with any pecuniary limitation on appeals directly from the circuit court to this Court.

This suit was brought in the Circuit Court of the United States for the District of Indiana by the Indiana Manufacturing Company, a corporation organized and existing under the laws of the State of Indiana, against Sterling R. Holt and others, taxing officers of Marion County, Indiana, and of a township in said county, and some others, constituting the board of review of that county, all of whom were citizens of Indiana, to enjoin the collection of certain personal taxes for the years 1892, 1893, 1894, and 1895, assessed upon the capital stock and tangible property of the company. The bill alleged that the larger part of the assessment made by the taxing authorities was for the supposed value of certain rights under letters patent from the United States owned by the company, and which the company insisted were not subject to taxation by the state authorities; that the capital stock, aside from the tangible property, represented solely the supposed value of the letters patent, and that the taxes in respect of the tangible property had been paid by the company. Complainant charged that the assessment was illegal, unconstitutional, and void, and averred that the suit was instituted

to redress the deprivation, under color of a law of the State of Indiana, of a right secured by the laws of the United States, and, further, that it is a suit arising under the patent laws of the United States.

The circuit court entered a decree, in accordance with the prayer of the bill, perpetually enjoining the collection of the taxes claimed to be due in respect of the capital stock insofar as the value thereof was derived from patent rights or letters patent owned by complainant. An appeal was taken to the Circuit Court of Appeals for the Seventh Circuit, and dismissed by that court for want of jurisdiction. 80 F. 1.

The circuit court of appeals held that the suit was not one arising under the patent laws of the United States, and that, as the jurisdiction of the circuit court could rest only on the ground that the constitutional rights of complainant were infringed by the laws of the State of Indiana which were repugnant to and in contravention of the Constitution of the United States, an appeal would not lie to that court, and could only be taken directly to this Court under section five of the Judiciary Act of March 3, 1891.