Argued: November 5, 2007 -- Decided: December 4, 2007
Opinion Author: Roberts
Under Georgia law, most commercial and industrial property is valued locally by county boards for tax purposes, but public utilities such as petitioner railroad (CSX) are initially valued by the State. In 2002, respondent Georgia state board used a different combination of methodologies than it had in 2001 to determine that the market value of CSX's in-state real property had increased 47 percent, resulting in a significantly higher ad valorem tax levy. CSX filed suit under the Railroad Revitalization and Regulatory Reform Act of 1976 (4-R Act or Act), which bars States from, inter alia, "[a]ssess[ing] rail transportation property at a value that has a higher ratio to the [property's] true market value ... than the ratio" between the assessed and true market values of other commercial and industrial property in the same taxing jurisdiction, 49 U. S. C. sec.11501(b)(1), and authorizes the federal district court to enjoin the tax if the railroad ratio exceeds the ratio for other property by at least five percent, sec.11501(c). CSX alleged that Georgia had grossly overestimated the market value of its in-state rail property while accurately valuing other commercial and industrial property in the State, so that CSX's property was taxed at a ratio of assessed-to-market value considerably more than 5 percent greater than the same ratio for the other in-state property. Ruling that Georgia had not discriminated against CSX in violation of the 4-R Act because the State had used widely accepted valuation methods to arrive at its 2002 estimate of true market value, the District Court declared that the Act does not allow a railroad to challenge a State's chosen methodology if it is rational and not motivated by discriminatory intent. The Eleventh Circuit panel affirmed, reasoning that the Act does not clearly state that railroads may challenge valuation methodologies, and that such a clear statement was required in light of the intrusion on state taxing prerogatives.
Held: The 4-R Act allows a railroad to attempt to show that state methods for determining the value of railroad property result in a discriminatory determination of true market value. Pp. 5-12.
(a) The Act's language is clear. States may not tax railroad property at a ratio of assessed-to-true-market value higher than the ratio for other commercial and industrial property in the same jurisdiction. To apply the Act, district courts must calculate the true market value of in-state railroad property. A court cannot undertake the comparison of ratios the statute requires without that figure at hand, see Burlington Northern R. Co. v. Oklahoma Tax Comm'n, 481 U. S. 454 , and the determination of true market value may be affected by the State's choice of valuation methods. Georgia's argument that valuation methodologies must be distinguished from their application, and that the Act allows courts to question only the latter, is rejected. There is no distinction between method and application in the Act's language and no passage limiting district court factfinding as the State proposes. Georgia's position is untenable given the way market value is calculated. Valuation is not a matter of mathematics, but an applied science, even a craft. Most appraisers estimate market value by employing not one methodology but a combination because no one approach is entirely accurate, at least in the absence of an established market for the type of property at issue. The individual methods yield sometimes more, sometimes less reliable results depending on the peculiar features of the property evaluated. Given the extent to which the chosen methods can affect the determination of value, preventing courts from scrutinizing state valuation methodologies would render sec.11501 a largely empty command, forcing district courts to accept as "true" the market value estimate of the State, one of the parties to the litigation. States, in turn, would be free to employ appraisal techniques that routinely overestimate the market worth of railroad assets. By then levying taxes based on those overestimates, States could implement the very discriminatory taxation Congress sought to eradicate. Courts would be powerless to stop them, and the Act would ultimately guarantee railroads nothing more than mathematically accurate discriminatory taxation.
The State's warning that allowing railroads to introduce their own valuation estimates based on different methodologies will inevitably lead to a futile clash of experts, which courts will have no reasonable way to settle, is not compelling, given that Congress was not similarly troubled. Rather, Congress directed courts to find true market value, however elusive, making that value the objective benchmark for courts' evaluation. Property valuation, though admittedly complex, is at bottom just "an issue of fact about possible market prices," Suitum v. Tahoe Regional Planning Agency, 520 U. S. 725 , an issue district courts are used to addressing. In light of the statute's directive making true market value a factual question to be determined by the district court, what Georgia really seeks is to limit the types of evidence courts may consider as part of their factual inquiry. Had Congress intended to impose such a limit, it could easily have included language insulating the State's chosen methodologies from judicial scrutiny. It did not. Pp. 5-9.
(b) The State argues that any interpretation of the Act allowing courts to question state valuation methods ignores the background principles of federalism against which the statute was enacted. Even if important state policy questions are intertwined with the selection of a valuation methodology, however, Congress clearly permitted courts to question such methodologies when it banned discriminatory assessment ratios and made true market value a question to be litigated in federal court. Department of Revenue of Ore. v. ACF Industries, Inc., 510 U. S. 332 , distinguished. The Court also disagrees with Georgia's claim that the Court's interpretation will destroy the States' discretion to choose their own valuation methodologies. A State may use whatever method it likes, so long as the result is not discriminatory in violation of the Act. Pp. 9-12.
472 F. 3d 1281, reversed.Roberts, C. J., delivered the opinion for a unanimous Court.
Argued: October 30, 2007 -- Decided: December 4, 2007
Opinion Author: Ginsburg
Under federal law, the maximum prison term for a felon convicted of possessing a firearm is ordinarily 10 years. See 18 U. S. C. sec. 924(a)(2). If the offender's prior criminal record includes at least three convictions for "violent felon[ies,]" however, the Armed Career Criminal Act of 1984 (ACCA) mandates a minimum term of 15 years. See sec. 924(e)(1). Congress defined the term "violent felony" to include specified crimes "punishable by imprisonment for a term exceeding one year," sec. 924(e)(2)(B), but also provided that a state-law misdemeanor may qualify as a "violent felony" if the offense is punishable by a term of more than two years, sec. 921(a)(20)(B). Congress amended sec. 921(a)(20) in 1986 to exclude from qualification for enhanced sentencing "any conviction which has been expunged, or set aside or for which a person has been pardoned or has had civil rights [i.e., rights to vote, hold office, and serve on a jury] restored."
Petitioner Logan pleaded guilty to being a felon in possession of a firearm and received a 15-year sentence, the mandatory minimum under ACCA. In imposing this sentence, the court took account of three Wisconsin misdemeanor battery convictions, each of them punishable by a 3-year maximum sentence, and none of them revoking any of Logan's civil rights. Logan challenged his sentence on the ground that his state-court convictions fell within sec. 921(a)(20)'s "civil rights restored" exemption from ACCA's reach. Rights retained, Logan argued, should be treated the same as rights revoked but later restored. The District Court disagreed, holding that the exemption applies only to defendants whose civil rights were both lost and restored, and the Seventh Circuit affirmed.
Held: The exemption contained in sec. 921(a)(20) does not cover the case of an offender who retained civil rights at all times, and whose legal status, postconviction, remained in all respects unaltered by any state dispensation. Pp. 6-13.
(a) The ordinary meaning of the word "restored"--giving back something that has been taken away--does not include retention of something never lost. Moreover, the context in which "restored" appears in sec. 921(a)(20) counsels adherence to the word's ordinary meaning. In sec. 921(a)(20), the words "civil rights restored" appear in the company of "expunged," "set aside," and "pardoned." Each of those terms describes a measure by which the government relieves an offender of some or all of the consequences of his conviction. In contrast, a defendant who retains rights is simply left alone. He receives no status-altering dispensation, no token of forgiveness from the government. Pp. 6-7.
(b) Logan's dominant argument against a plain-meaning approach is not persuasive. He relies on the harsh result a literal reading could yield: Unless retention of rights is treated as legally equivalent to restoration of rights, he maintains, less serious offenders will be subject to ACCA's enhanced penalties while more serious offenders in the same State, who have had civil rights restored, may escape heightened punishment. Logan urges that this result is not merely anomalous; it is absurd, particularly in States where restoration of civil rights occurs automatically upon release from prison. Pp. 7-8.
Logan's harsh or absurd consequences argument overlooks sec. 921(a)(20)'s "unless" clause, under which an offender gains no exemption from ACCA's application through an expungement, set aside, pardon, or restoration of civil rights if the dispensation "expressly provides that the [offender] may not ship, transport, possess, or receive firearms." Many States that restore felons' civil rights (or accord another measure of forgiveness) nonetheless impose or retain firearms disabilities. Further, Wisconsin no longer punishes misdemeanors by more than two years' imprisonment, and thus no longer has any misdemeanors that qualify as ACCA predicates. Pp. 8-9.
The resolution Logan proposes, in any event, would correct one potential anomaly while creating others. Under Logan's proposed construction, all crimes, including first-degree murder, would be treated as crimes for which "civil rights [have been] restored" in a State that does not revoke any offender's civil rights, while less serious crimes committed elsewhere would not. Accepting Logan's argument would also undercut sec. 921(a)(20)(B), which subjects to ACCA state misdemeanor convictions punishable by more than two years' imprisonment. Because misdemeanors generally entail no revocation of civil rights, reading the word "restored" to include "retained" would yield this curiosity: An offender would fall within ACCA's reach if his three prior offenses carried potential prison terms of over two years, but would be released from ACCA's grip by virtue of his retention of civil rights. This Court is disinclined to say that what Congress imposed with one hand (exposure to ACCA) it withdrew with the other (exemption from ACCA). Even assuming that when Congress revised sec. 921(a)(20) in 1986, it labored under the misapprehension that all misdemeanants and felons at least temporarily forfeit civil rights, and indulging the further assumption that courts may repair such a congressional oversight or mistake, this Court is not equipped to say what statutory alteration, if any, Congress would have made had its attention trained on offenders who retained civil rights; nor can the Court recast sec. 921(a)(20) in Congress' stead. Pp. 9-11.
Section 922(g)(9)--which was adopted 10 years after sec. 921(a)(20) was given its current shape and which outlaws possession of a firearm by anyone "convicted ... of a misdemeanor crime of domestic violence"--cautions against any assumption that Congress did not mean to deny the sec. 921(a)(20) exemption to offenders who retained their civil rights. Tailored to sec. 922(g)(9), Congress adopted a definitional provision, sec. 921(a)(33)(B)(ii), corresponding to sec. 921(a)(20), which specifies expungement, set aside, pardon, or restoration of rights as dispensations that can cancel lingering effects of a conviction. That provision also demonstrates that the words "civil rights restored" do not cover a person whose civil rights were never taken away. It provides for restoration of civil rights as a qualifying dispensation only "if the law of the applicable jurisdiction provides for the loss of civil rights" in the first place. Section 921(a)(33)(B)(ii) also rebuts Logan's absurdity argument. Statutory terms may be interpreted against their literal meaning where the words could not conceivably have been intended to apply to the case at hand. See, e.g., Green v. Bock Laundry Machine Co., 490 U. S. 504 . In sec. 921(a)(33)(B)(ii), however, Congress explicitly distinguished between "restored" and "retained," thereby making it more than conceivable that the Legislature, albeit an earlier one, meant to do the same in sec. 921(a)(20). Pp. 11-13.
453 F. 3d 804, affirmed.Ginsburg, J., delivered the opinion for a unanimous Court.