Charles Evans Hughes

“ We are not concerned with any question of the state's policy in imposing taxes, or with the various methods employed in the levee district, apart from the application of the Fourteenth Amendment. The question as to the validity of the act of 1926 is raised only by the state tax collector in his official capacity, as one acting solely under the authority of the Legislature whose requirement he contests. The only person taxed by the statute whose rights are before the court is the petitioner, which seeks to uphold the state legislation which defines its liability and with which it has complied. ”

“ The petitioner also offered to prove, and the fact was stipulated subject to objection, that the state tax commission had assessed for ad valorem taxes the railroad of the petitioner within the levee district at $1,000 a mile, and that of the other railroad at $32,000 a mile, and, further, that in the classification of railroads by the state railroad commission for the purpose of levying a privilege tax the petitioner was placed with respect to its main line in class 3 and the other railroad in class 1. ”

“ New York, 165 U.S. 628, 633, 634, 17 S.C.t. 418, 41 L. Ed. 853) , and statutes requiring a minimum number of men in train crews but not applying to railroads of less than a stated mileage (Chicago, Rock Island & Pacific Railway Co. v. Arkansas, 219 U.S. 453, 31 S.C.t. 275, 55 L. Ed. 290; St. Louis, Iron Mountain & Southern Railway Co. v. Arkansas, 240 U.S. 518, 36 S.C.t. 443, 60 L. Ed. 776) . ”