This case concerned efforts by the State of Tennessee and several counties to collect taxes assessed on the Mobile and Ohio Railroad Company's property, roadbed, and fixtures for the years 1887 through 1889. The railroad defended on the ground that these levies impaired the contract contained in an exemption clause of its 1848 Tennessee charter, which exempted the road from taxation for twenty-five years after completion and barred any tax that would reduce dividends below eight percent. The U.S. Supreme Court held that the twenty-five-year exemption had expired in 1886 and that the eight-percent clause did not create a continuing exemption but instead prescribed a special and discriminatory rule of taxation. The Court reasoned that the charter language plainly limited the exemption's duration, that the clause conflicted with the uniformity requirement of the state constitution of 1834, and that any ambiguity would be resolved against the claim of perpetual tax relief.
The case concerned whether a lease entered into by a court-appointed receiver for railroad property was valid and binding on the trust without prior court approval. The court held that the lease lacked legal validity because the appointing order did not authorize such a contract involving significant expenditures extending beyond the receivership, and it was neither reported nor confirmed by the court. Receivers may handle ordinary daily expenses without approval but require court sanction for major contracts to bind the trust property. The Supreme Court affirmed the lower court's decision denying the lessor's claim for the unexpired term of the lease.
The case Loud v. Pomona Land & Water Co. involved contracts for the purchase of land and associated irrigation company stock, in which the buyer made initial payments but refused to pay the remaining installments, prompting the seller to sue for the balance. The court decided that the buyer's covenant to pay the purchase price was independent of the seller's covenant to convey, so the land company could enforce payment without first tendering a deed or conveyance. Core reasoning was that the contracts' unambiguous language made full payment and performance by the buyer a condition precedent to the seller's obligation to convey, and other asserted defenses such as fraud, lack of title, or pre-contract representations were either irrelevant to the written terms or unsupported by proof.
The case concerned whether the Northern Pacific Railroad remained liable for a 3% gross earnings tax for 1889 under an 1889 Dakota Territory statute after accepting its terms. The 1883 compulsory gross-earnings tax law had been repealed and replaced by the 1889 act, which allowed railroads to elect either ordinary property taxation or the percentage tax in exchange for paying prior arrearages and current-year amounts by set deadlines. The railroad accepted the new act, paid arrearages for 1886-1888, but did not pay or tender the 1889 amount due August 15, 1889; the act was later repealed by North Dakota's constitution upon statehood. The court held that acceptance of the 1889 act created an obligation to pay the 1889 percentage that was not extinguished by the subsequent repeal, because the statute conditioned its benefits on timely payment of both arrearages and the current year's tax.
This case concerned whether a U.S. Circuit Court had jurisdiction under the Customs Administrative Act of 1890 to review a board of general appraisers' reversal of a collector's decision on converting Austrian paper florins to U.S. currency for calculating import duties on china and glassware. The collector had used the proclaimed gold florin value of $0.482, leading to higher duties, while the board directed use of the silver value of $0.32; the Circuit Court dismissed the collector's petition for lack of jurisdiction over non-classification or non-rate issues. The Supreme Court held that the Circuit Court possessed jurisdiction because sections 14 and 15 of the Act allow review of the board's decisions on questions of law and fact within its appellate scope, excluding only final dutiable value determinations under section 13, and the currency valuation here fell within reviewable matters. The Court reversed the dismissal and remanded for further proceedings.
The case concerned Sidney Pridgeon, who was convicted in 1891 of horse stealing in the Indian country attached to Oklahoma Territory and sentenced by a federal territorial court to five years' imprisonment with hard labor plus costs in an Ohio state penitentiary. Pridgeon sought a writ of habeas corpus in federal circuit court, claiming lack of jurisdiction over the offense and that the hard labor component made the entire sentence void. The circuit court discharged him solely on the hard labor ground without addressing jurisdiction. On certified questions from the court of appeals, the Supreme Court held that the offense was no longer punishable under the cited federal statute after the 1890 creation of Oklahoma Territory, that the indictment was not fatally defective on collateral attack, and that the sentence was not void because of the hard labor addition. The Court reasoned that habeas corpus relief cannot equate to an acquittal when only part of a sentence exceeds authority, and the valid five-year imprisonment term remained enforceable under the statute authorizing the writ.
