hillsborough
somerset
county
cromwell
argued
decided
january
harry
walburg
newark
petitioners
charles
hughes
new
york
city
shelton
pitney
newark
respondent
justice
douglas
delivered
opinion
action
brought
respondent
declaratory
judgment
act
judicial
code
declared
null
void
certain
assessments
intangible
personal
property
entered
years
collector
hillsborough
township
somerset
county
new
jersey
jurisdiction
federal
new
jersey
invoked
reason
diversity
citizenship
allegation
taxing
authorities
consistently
systematically
intentionally
singled
respondent
discriminatory
treatment
assessment
taxes
without
remedy
laws
decisions
new
jersey
prayed
assessments
declared
invalid
contravention
due
process
equal
protection
clauses
fourteenth
amendment
provisions
applicable
new
jersey
statutes
later
refer
district
denied
motion
dismiss
gave
judgment
respondent
circuit
appeals
affirmed
case
petition
writ
certiorari
granted
asserted
conflict
decision
great
lakes
dredge
dock
huffman
raised
important
problem
concerning
relationship
federal
courts
state
taxing
authorities
sec
judicial
code
provides
suits
equity
shall
sustained
federal
courts
case
plain
adequate
complete
remedy
may
law
principle
long
recognized
force
cases
federal
courts
asked
enjoin
collection
state
tax
matthews
rodgers
cases
cited
scrupulous
regard
rightful
independence
state
governments
times
actuate
federal
courts
proper
reluctance
interfere
injunction
fiscal
operations
require
relief
denied
every
case
asserted
federal
right
may
preserved
without
page
page
remedy
law
adequate
complete
one
must
pursued
even
protection
federal
right
practice
federal
equity
courts
given
recognition
tion
congress
johnson
act
stat
amended
stat
judicial
code
provides
district
shall
jurisdiction
suit
enjoin
suspend
restrain
assessment
levy
collection
tax
imposed
pursuant
laws
state
plain
speedy
efficient
remedy
may
law
equity
courts
state
background
held
great
lakes
dredge
dock
huffman
supra
policy
led
federal
courts
equity
refrain
enjoining
collection
allegedly
unlawful
state
taxes
likewise
govern
exercise
discretion
withholding
relief
declaratory
judgments
act
circuit
appeals
fully
recognized
principle
huffman
case
concluded
state
procedure
efficient
adequate
protect
federal
right
discriminatory
state
taxation
around
conclusion
first
phase
controversy
turns
equal
protection
clause
fourteenth
amendment
protects
individual
state
action
sel
cts
discriminatory
treatment
subjecting
taxes
imposed
others
class
right
right
equal
treatment
may
complain
equality
achieved
increasing
taxes
members
class
level
constitutional
requirement
however
satisfied
state
remove
discrimination
imposes
discrimination
directed
burden
seeking
upward
revision
taxes
members
class
sioux
city
bridge
dakota
county
moines
bank
bennett
cumberland
local
board
revision
courts
new
jersey
long
line
held
taxpayer
singled
discriminatory
taxation
may
obtain
equalization
reduction
assessment
remedy
restricted
proceedings
members
class
purpose
taxes
increased
rule
stated
royal
mfg
board
equalization
affirmed
follows
county
boards
required
secure
taxation
property
true
value
fact
property
assessed
true
value
property
taxpayers
within
district
assessed
true
value
affords
ground
demanding
reduction
valuation
though
entitle
apply
increase
valuation
others
pages
page
basis
rule
plain
state
remedy
adequate
protect
respondent
rights
federal
constitution
argued
however
new
jersey
courts
adopted
different
rule
central
state
tax
department
decided
errors
appeals
case
entertain
objection
particular
tax
assessment
violated
rule
sioux
city
bridge
dakota
county
supra
found
complaining
taxpayer
shown
discrimination
within
meaning
cases
existed
argued
highest
new
jersey
recognized
federal
rule
federal
district
remitted
respondent
remedy
new
jersey
courts
however
difficulty
position
first
place
judge
wrote
opinion
errors
appeals
case
wrote
opinion
new
jersey
year
later
lehigh
valley
state
board
taxpayer
contended
state
board
tax
appeals
erred
refusing
admit
evidence
discrimination
argument
rule
sioux
city
bridge
dakota
county
supra
followed
holding
royal
mfg
board
equalization
supra
disapproved
new
jersey
declined
allow
writ
certiorari
review
judgments
state
board
tax
appeals
mention
martin
case
followed
royal
mfg
board
equalization
supra
saying
new
jersey
law
point
controlling
page
therefore
may
well
true
respondent
ays
case
simply
decided
point
raised
taxpayer
supported
facts
found
unnecessary
consider
whether
systematic
discrimination
shown
new
jersey
afforded
adequate
remedy
event
uncertainty
concerning
new
jersey
remedy
make
speculative
wallace
hines
whether
state
affords
full
protection
federal
rights
second
place
state
board
tax
appeals
respondent
might
appealed
concededly
right
pass
constitutional
questions
judgments
may
reviewed
new
jersey
certiorari
allowance
writ
however
matter
right
purely
discretionary
refusal
writ
certiorari
may
judicially
reviewed
errors
appeals
accordingly
conclude
uncertainty
surrounding
adequacy
state
remedy
justify
district
retaining
jurisdiction
cause
charges
discrimination
complaint
denied
jurisdiction
district
determined
allegations
bill
hart
keith
vaudeville
exchange
substantial
brings
us
second
phase
controversy
neither
district
circuit
appeals
decided
case
federal
grounds
held
reliance
duke
power
state
board
assessments
invalid
new
jersey
statutes
case
present
one
property
assessment
attempted
assessed
county
board
taxpayer
april
tax
years
involved
without
notice
hearing
assessment
set
aside
conformity
statute
held
remedial
designed
cure
irregularities
assessing
levying
taxes
apply
statute
addition
property
omitted
assessment
complied
page
page
petitioner
argues
clear
duke
power
state
board
supra
respondent
remedy
state
tribunals
failure
petitioner
follow
procedure
required
new
jersey
statutes
federal
required
pursue
held
federal
constitutional
question
turns
interpretation
local
law
local
law
doubt
proper
procedure
federal
hold
case
definite
determination
local
law
made
state
courts
railroad
commission
texas
pullman
chicago
fieldcrest
dairies
spector
motor
service
mclaughlin
latter
case
involved
suit
constitutionality
connecticut
tax
challenged
uncertainty
concerning
meaning
local
law
one
construction
constitutional
issues
fall
event
decision
state
courts
cause
constitutional
issues
formulated
authoritative
rather
speculative
way
clear
available
state
remedy
complainant
resort
remand
cause
present
case
appears
respondent
opportunity
appeal
state
board
tax
expired
even
district
ruled
motion
dismiss
clear
today
respondent
open
adequate
remedy
new
jersey
courts
challenging
assessments
local
law
grounds
moreover
duke
power
state
board
supra
decided
shortly
district
rendered
gave
authoritative
interpretation
local
law
hence
reason
holding
case
spector
motor
service
mclaughlin
supra
remitting
complainant
state
courts
determination
local
law
question
longer
existent
follows
fortiori
bill
dismissed
stated
greene
louisville
remedy
law
considered
adequate
prevent
equitable
relief
unless
covers
entire
case
made
bill
equity
though
availability
state
remedy
local
law
question
assumed
exist
much
uncertainty
surrounds
new
jersey
remedy
protect
taxpayer
federal
right
refusal
dismiss
bill
proper
exercise
discretion
thus
however
case
may
viewed
exceptional
circumstances
noted
take
general
rule
great
lakes
dredge
dock
huffman
supra
district
therefore
properly
proceeded
decide
case
merits
placed
decision
local
law
grounds
objectionable
federal
jurisdiction
may
pass
whole
case
agreeably
desired
practice
decide
local
law
questions
without
reaching
constitutional
issues
siler
louisville
greene
louisville
supra
page
page
chicago
great
kendall
risty
chicago
ry
waggoner
estate
wichita
county
hurn
oursler
petitioner
makes
extended
argument
effect
duke
power
state
board
supra
trolling
precedent
local
law
question
decision
turned
questions
pay
great
deference
views
judges
courts
familiar
intricacies
trends
local
law
practice
huddleston
dwyer
unable
say
district
circuit
appeals
erred
applying
case
rule
duke
power
state
board
involved
closely
analogous
facts
affirmed
justice
murphy
justice
jackson
took
part
consideration
decision
case
footnotes
assessments
call
tax
payments
nearly
year
compared
township
budget
something
like
annually
prior
assessments
net
assessed
valuation
taxation
property
assessed
real
personal
township
amounted
resulting
tax
rate
per
cent
per
cent
additional
assessments
respondent
apparently
increased
valuation
township
tax
ratables
two
tax
years
though
affected
tax
rates
years
state
collector
randolph
state
taylor
state
koster
state
segoine
affirmed
central
state
board
royal
mfg
board
equalization
pennsylvania
coal
saddle
river
duke
power
hillsborough
township
misc
reversed
another
point
duke
power
state
board
tax
appeals
schwartz
essex
county
board
affirmed
staubach
cities
service
oil
post
anderson
staubach
cities
service
oil
supra
note
provides
part
written
complaint
collector
taxpayer
taxing
district
governing
body
thereof
property
specified
omitted
assessment
county
board
five
days
notice
writing
owner
party
complaining
due
examination
hearing
may
enter
omitted
property
duplicate
judgment
rendered
within
ten
days
hearing
transcript
whereof
shall
furnished
board
collector
shall
amend
duplicate
accordingly
different
procedure
provided
inclusion
property
assessor
discussion
difference
two
types
assessments
see
duke
power
state
board
supra
pages
pages
page
page
said
property
taxing
district
omitted
assessor
must
added
assessment
april
addition
decreases
amount
taxes
raised
since
ratables
thereby
increased
taxpayer
embarrassed
knows
tax
pay
liable
anyway
even
property
cluded
assessment
however
property
added
assessment
rate
fixed
gives
rise
municipal
windfall
harm
due
notice
fair
hearing
county
board
judicial
determination
sec
provides
tax
assessment
water
rate
imposed
levied
state
shall
set
aside
reversed
action
suit
proceeding
irregularity
defect
form
illegality
assessing
laying
levying
tax
assessment
water
rate
proceeding
collection
person
property
upon
assessed
laid
fact
liable
taxation
assessment
imposition
water
rate
respect
purposes
tax
assessment
rate
levied
assessed
laid
sec
provides
action
suit
proceeding
shall
pending
review
tax
assessment
water
rate
shall
amend
irregularities
errors
defects
may
necessary
ascertain
determine
sum
person
property
legally
liable
order
decree
fix
amount
thereof
sum
fixed
shall
amount
tax
assessment
water
rate
person
property
shall
liable
duke
power
state
board
supra
page
page
stated
remedial
statutes
find
substitute
proper
assessment
application
instances
properly
omitted
assessor
assessed
name
one
true
owner
ninety
days
allowed
state
board
tax
appeals
rule
cch
tax
serv
par
resolutions
county
board
attempting
make
assessments
entered
june
present
bill
filed
july
answer
september
motion
dismiss
november
order
denying
motion
dismiss
made
august
seems
certain
circumstances
certiorari
may
lieu
appeal
state
board
tax
appeals
held
schwartz
essex
county
board
supra
note
lack
jurisdiction
county
board
irregularity
proceedings
may
tested
certiorari
page
see
state
clothier
seen
note
supra
discretionary
writ
case
decided
errors
appeals
march
present
case
decided
district
july