Volume 598 U. S. Part 2 Pages 631–650

OFFICIAL REPORTS OF

THE SUPREME COURT May 25, 2023

Page Proof Pending Publication

REBECCA A. WOMELDORF reporter of decisions

NOTICE: This preliminary print is subject to formal revision before the bound volume is published. Users are requested to notify the Reporter of Decisions, Supreme Court of the United States, Washington, D.C. 20543, pio@supremecourt.gov, of any typographical or other formal errors. OCTOBER TERM, 2022 631

Syllabus

TYLER v. HENNEPIN COUNTY, MINNESOTA, et al. certiorari to the united states court of appeals for the eighth circuit No. 22–166. Argued April 26, 2023—Decided May 25, 2023 Geraldine Tyler owned a condominium in Hennepin County, Minnesota, that accumulated about $15,000 in unpaid real estate taxes along with interest and penalties. The County seized the condo and sold it for $40,000, keeping the $25,000 excess over Tyler's tax debt for itself. Minn. Stat. §§ 281.18, 282.07, 282.08. Tyler fled suit, alleging that the County had unconstitutionally retained the excess value of her home above her tax debt in violation of the Takings Clause of the Fifth Amendment and the Excessive Fines Clause of the Eighth Amendment. The District Court dismissed the suit for failure to state a claim, and the Eighth Circuit affrmed. Held: Tyler plausibly alleges that Hennepin County's retention of the ex- cess value of her home above her tax debt violated the Takings Clause. Pp. 636–648. Page Proof Pending Publication (a) Tyler's claim that the County illegally appropriated the $25,000 surplus constitutes a classic pocketbook injury suffcient to give her standing. TransUnion LLC v. Ramirez, 594 U. S. –––, –––. Even if there are debts on her home, as the County claims, Tyler still plausibly alleges a fnancial harm, for the County has kept $25,000 that she could have used to reduce her personal liability for those debts. Pp. 636–637. (b) Tyler has stated a claim under the Takings Clause, which pro- vides that “private property [shall not] be taken for public use, without just compensation.” Whether remaining value from a tax sale is prop- erty protected under the Takings Clause depends on state law, “tradi- tional property law principles,” historical practice, and the Court's precedents. Phillips v. Washington Legal Foundation, 524 U. S. 156, 165–168. Though state law is an important source of property rights, it cannot be the only one because otherwise a State could “sidestep the Takings Clause by disavowing traditional property interests” in assets it wishes to appropriate. Id., at 167. History and precedent dictate that, while the County had the power to sell Tyler's home to recover the unpaid property taxes, it could not use the tax debt to confscate more property than was due. Doing so effected a “classic taking in which the government directly appropriates private property for its own use.” Tahoe-Sierra Preservation Council, Inc. v. Tahoe Re- gional Planning Agency, 535 U. S. 302, 324 (internal quotation marks omitted). 632 TYLER v. HENNEPIN COUNTY

Syllabus

The principle that a government may not take from a taxpayer more than she owes is rooted in English law and can trace its origins at least as far back as the Magna Carta. From the founding, the new Govern- ment of the United States could seize and sell only “so much of [a] tract of land . . . as may be necessary to satisfy the taxes due thereon.” Act of July 14, 1798, § 13, 1 Stat. 601. Ten States adopted similar statutes around the same time, and the consensus that a government could not take more property than it was ow