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Lake Superior Consolidated Iron Mines v. Lord, 271 U.S. 577 (1926)

Lake Superior Consolidated Iron Mines v. Lord

Nos. 336, 355, 388, 389, 390, 391, and 471

Argued December 8, 9, 1925

Decided June 7, 1926

271 U.S. 577


1. The obligation of an outstanding contract is not impaired, contrary to Const. Art. I, § 10, by a later state statute taxing the proceeds of the contract. P. 271 U. S. 581.

2. Minnesota Laws of 1923, c. 226, directing levy and collection of a tax of 6 percent on royalties received for permission to explore, mine, take out, and remove ore from land in the state, may be reasonably interpreted as laying a tax upon interests in mineral lands from which permission has been given to extract ores upon payment of royalty, the amount of the exaction being determined by reference to the sum actually received for the use of such interests, Von Baumbach v. Sargent Land Co., 242 U. S. 305, and does not violate the requirement of the state constitution that "taxes shall be uniform upon the same class of subjects and shall be levied and collected for public purposes," or the due process clause of the Fourteenth Amendment. P. 271 U. S. 581.

3. As the tax is laid upon land, neither the owner's residence nor the place fixed for payment of the royalty is important. P. 271 U. S. 582.

4. Ore lands being a distinct class of property, the tax is consistent with the equal protection clause of the Fourteenth Amendment without being extended to other classes such as quarries and forests. P. 271 U. S. 582.

Page 271 U. S. 578

5. The state legislature may exercise wide discretion in selecting the subjects of taxation so long as it refrains from clear and hostile discrimination against particular persons or classes. P. 271 U. S. 582.


Appeals from decrees of the district court dismissing the bills in suits against the Tax Commission of the State of Minnesota to enjoin them from enforcing a tax on royalties from ore lands.

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