Berryman v. Board of Trustees of Whitman College

Citations

• 222 U.S. 334
• 32 S. Ct. 147
• 56 L. Ed. 225
• 1912 U.S. LEXIS 2185

Syllabus

<p>The amount in controversy where the question is whether a contract of exemption from taxation has been impaired by subsequent legislation is measured by the value of the right to be protected and not by a mere isolated element, such as the tax for a single year.</p> <p>In this case the jurisdictional value of amount in controversy held to exceed $2,000, although the actual tax, the collection whereof was sought to be enjoined on the ground that its imposition impaired the obligation of a legislative contract, was less than $2,000.</p> <p>Cases, in which the jurisdictional value of amount in controversy is limited to the single tax involved, reviewed and distinguished.</p> <p>The act of March 2, 1867, 14 Stat. 426, now Rev. Stat., § 1889, prohibiting the granting by territorial legislatures of especial privileges. related to conferring new privileges on existing corporations as well as to granting privileges in original charters; and the prohibition' included all especial privileges such ás 'exemption from taxation..</p> <p>In construing a statute the court must be controlled by the power manifested by the act and not by the motive which initiated it; the scope of the act may extend heyond the generating caus.es thereof.</p> <p>The rule that- exemptions from taxation must be strictly construed against the exemption is as broad as the subject to which it relates; the rule applies not only to the extent of the legislative grant itself but also to the power of the legislature to make it.</p> <p>A contract for exemption from taxation is an-especial'privilege, and is none the less within the prohibitions of § 1889, Rev. Stat., because granted to an educational institution; it cannot be regarded as beyond the prohibition because granted as an equivalent.</p> <p>The fact that Congress failed to disapprove an act of a Territorial legislature does not validate it if the act was passed in direct violation of a prohibitive provision in the organic act. Clayton v. Utah, 132 U