Supreme Court of the United States

Township of Hillsborough v. Cromwell

January 28, 1946326 U.S. 620

Summary

The Court affirmed the judgment upholding the respondent's challenge to large assessments on intangible personal property. It held that the federal court properly retained jurisdiction because New Jersey's remedies were uncertain and inadequate to protect the asserted federal right, and it properly decided the case on state-law grounds rather than remitting the matter to state court. The Court also upheld application of the New Jersey rule that assessments of previously omitted property made after the statutory deadline, without the required notice and hearing, were invalid.

Holding

  • Adequacy of the state remedy and federal declaratory jurisdiction. The District Court properly retained jurisdiction because New Jersey's remedy for discriminatory taxation was uncertain and did not clearly provide an adequate means of protecting the respondent's asserted federal right.
  • Whether the federal court had to remit the local-law question to state court. The federal court was not required to hold the case for a state-court determination of local law because the relevant New Jersey precedent had already authoritatively interpreted the statute and the respondent's opportunity to pursue the available administrative remedy had expired.
  • Validity of the assessments under New Jersey law. The lower courts did not err in applying the New Jersey rule that property omitted from an assessment could not be added after the statutory deadline without compliance with the required notice, hearing, and procedural requirements; the assessments were therefore invalid.

Docket 305

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