Rorick v. Board of Com'rs of Everglades Drainage Dist.
District Court, N.D. Florida · 1932-04-13 · cited 24×
This 1932 case involved bondholders of the Everglades Drainage District suing Florida state officers and the district's board of commissioners to enjoin enforcement of provisions in 1929 and 1931 state laws that altered the board's composition and the handling of drainage taxes and tax-delinquent lands. The plaintiffs argued these changes impaired their bond contracts in violation of the Contract Clause and denied due process and equal protection under the Fourteenth Amendment. The district court, in a majority opinion, held that the laws could not validly impair the bondholders' contractual rights regarding tax collection and land disposition, and it granted an interlocutory injunction to prevent those effects. The core reasoning rested on precedents protecting bond obligations from subsequent state legislation that diminishes security or remedies, while distinguishing the trustees' duties over public lands from personal liability. A partial dissent addressed the trustees' obligations on tax certificates but concurred on other points.