Supreme Court of the United States

Riggs, Special Guardian v. Del Drago

November 9, 1942317 U.S. 95

Summary

The Supreme Court held that New York’s §124 of the Decedent Estate Law, which apportionates the federal estate tax among beneficiaries, does not conflict with the federal estate tax statutes and therefore is not unconstitutional under the Supremacy Clause or the Uniformity Clause. The Court reversed the New York Court of Appeals and remanded for further proceedings consistent with this opinion.

Holding

  • Whether New York §124 of the Decedent Estate Law is repugnant to the federal estate tax statutes and thus unconstitutional under the Supremacy Clause. The Court held that §124 is not in conflict with the federal estate tax law and therefore does not violate the Supremacy Clause.
  • Whether §124 violates the Constitution’s Uniformity Clause. The Court held that the application of §124 does not offend the Uniformity Clause because the ultimate incidence of the federal estate tax is governed by state law, which satisfies the requirement of geographical uniformity.

Docket 30

Cited authorities

  • 39 Stat. 756
  • 43 Stat. 253
  • 44 Stat. 9
  • 47 Stat. 169
  • 40 Stat. 1057

Cited by