Covington v. First Nat. Bank of Covington

Citations

• 198 U.S. 100
• 25 S. Ct. 562
• 49 L. Ed. 963
• 1905 U.S. LEXIS 1157

Syllabus

<p>A Federal court is not required to give a judgment in a state court any greater weight than is awarded to it in the courts of the State in which it was rendered. As it is the settled rule in Kentucky that an. adjudication in a suit for taxes is not an estoppel between the parties as to taxes of any other year, even though such adjudication involves the finding of an exemption by contract, not only as to taxes involved in the suit, but also as to all taxes that might be levied under the contract, the Federal courts will not enjoin the collection of taxes for subsequent years on the ground that their invalidity was adjudicated by such a judgment.</p> <p>The statute of Kentucky of March 21, 1900, taxing shares of national banks, from the years 1893 to 1900 and thereafter held, void and in conflict with § 5219, Rev. Stat., as to those portions which are retroactive as imposing a burden on the bank not borne by other moneyed corporations of the State, and valid and not in conflict with § 5219 as to taxes imposed thereafter.</p> <p>A difference in methods in assessing shares of national banks from that of taxing state banks does not necessarily amount to a discrimination, rendering the act invalid under § 5219, and justify the judicial interference of courts for the protection of the shareholders, unless it appears that the difference in method actually results in imposing a greater burden on the national banks than is imposed on other moneyed capital in the State.</p>