Law School Case Brief
Youngblood v. United States - 141 F.2d 912 (6th Cir. 1944)
The authority of ministerial officers is to be strictly construed as including only such powers as are expressly conferred, or necessarily implied.
The United States District Court for Eastern Michigan entered an order in the nature of a writ of mandamus, directing appellant Youngblood, individually and as Register of Deeds for Wayne County, Michigan, to accept and file notice of tax lien under internal revenue laws, when presented with a fifty-cent filing fee by the United States Collector of Internal Revenue, and to index the notice in a record book of United States tax liens. The entry of the order followed a hearing on the petition of the United States for an order to show cause. The basic facts are not disputed; but the legality of the order is challenged by the State of Michigan and defended by the United States of America. The State of Michigan argued that the notice of lien, as presented, was not in a form authorized by its statutes for filing; and that its Register of Deeds, was, therefore, not authorized to accept and file the notice. The United States concedes that the tax lien notice contained no description of the land of the delinquent taxpayer as directed by the Michigan statute, but insisted that no such description was necessary. The Government points to § 505 of the Revenue Act of 1942, Ch. 619, 56 Stat. 798, § 3672(a), of the Internal Revenue Code, 26 U.S.C.S. § 3672(a), as the controlling law of the case. The district court ordered Youngblood to accept the United States' notices of liens.
Did a mere inconvenience to federal tax officials in filing descriptions of the land supply a sound basis for the issuance of a writ of mandamus directing Youngblood, a state ministerial officer, to violate his duty of compliance with the state law under which he acted?
The appellate court reversed and ordered the petition for mandamus dismissed. The court found that the authority of ministerial officers was to be strictly construed as including only powers that were expressly conferred or necessarily implied. The register's acceptance of lien notices was conditioned upon the inclusion of a description of the land in the notice. The court held that mere inconvenience to federal tax officials in filing descriptions of the land did not supply a sound basis for the issuance of a writ of mandamus directing a state ministerial officer to violate his duty of compliance with the state law under which he acted.
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