## Facts

- Maine enacted a statute imposing an annual statewide property tax of 1.5 mills “for the support of common schools,” assessed on all property according to valuation, with proceeds paid into the state treasury as the “common school fund.”
- The statute directed distribution of one-third of the fund to cities, towns, and plantations based on the number of scholars, and two-thirds based on municipal valuation; it also required that apportioned funds be spent on schools established and controlled by the receiving municipality.
- Herbert J. Sawyer owned 12 lots in an unorganized township in Penobscot County and had one child of school age.
- Sawyer’s total state tax assessment was $21.51; $6.45 was attributable to the challenged statute.
- Sawyer filed a bill in equity seeking to enjoin the State Treasurer from collecting the portion of the tax created by the statute, claiming it violated the Maine Constitution (uniform taxation and school provisions) and the Fourteenth Amendment.
- The parties reported the case for determination on the stipulated ground that the only question was the statute’s constitutionality.

## Issues

1. Whether a uniform statewide school tax assessed on all property by valuation violates the Maine Constitution’s requirement that property taxes be apportioned and assessed equally according to just value because the resulting school expenditures are not geographically proportional.
2. Whether a statewide tax-and-distribution scheme for common schools is inconsistent with the Maine constitutional provision authorizing and requiring the Legislature to compel towns to support public schools at their own expense.
3. Whether taxing property in unorganized territories while distributing the fund only to cities, towns, and plantations denies equal protection under the Fourteenth Amendment.

## Decision

- The court upheld the statute as constitutional under the Maine and United States Constitutions.
- The court denied injunctive relief and dismissed the bill.
- The court concluded that the tax satisfied constitutional equality requirements because it was uniformly assessed on property according to valuation, and unequal local benefit did not render the tax unconstitutional.

## Legal Principles

- A constitutional requirement of equal apportionment of property taxes is satisfied when the tax is uniformly imposed on the same class of property at a uniform rate based on just valuation; equality does not require proportional benefits to each taxpayer or locality.
- A constitutional mandate that towns support public schools at their own expense does not bar the Legislature from supplementing school support through statewide taxation and statewide distribution measures.
- Under equal protection, a generally applicable tax and a school-fund distribution system will be sustained if the classifications used are not arbitrary and the scheme bears a rational relation to the legitimate public purpose of supporting public education.

## Conclusion

The court sustained Maine’s statewide common-school property tax and its distribution formula, holding that uniform assessment by valuation satisfied state uniform-tax requirements, the school-support provision did not forbid state supplementation, and the distribution scheme did not violate equal protection.


Sawyer v. Gilmore, 83 A. 673 (Me. 1912)