{
  "id": 5196616,
  "name": "The People ex rel. M. R. Storm, County Collector, Appellant, vs. The Eastern Illinois and St. Louis Railroad Company, Appellee",
  "name_abbreviation": "People ex tel. Storm v. Eastern Illinois & St. Louis Railroad",
  "decision_date": "1927-12-21",
  "docket_number": "No. 18542",
  "first_page": "177",
  "last_page": "178",
  "citations": [
    {
      "type": "official",
      "cite": "328 Ill. 177"
    }
  ],
  "court": {
    "name_abbreviation": "Ill.",
    "id": 8772,
    "name": "Illinois Supreme Court"
  },
  "jurisdiction": {
    "id": 29,
    "name_long": "Illinois",
    "name": "Ill."
  },
  "cites_to": [],
  "analysis": {
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    "simhash": "1:62020ce18cff4f42",
    "word_count": 458
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  "last_updated": "2023-07-14T19:39:12.602080+00:00",
  "provenance": {
    "date_added": "2019-08-29",
    "source": "Harvard",
    "batch": "2018"
  },
  "casebody": {
    "judges": [],
    "parties": [
      "The People ex rel. M. R. Storm, County Collector, Appellant, vs. The Eastern Illinois and St. Louis Railroad Company, Appellee."
    ],
    "opinions": [
      {
        "text": "Mr. Chief Justice Heard\ndelivered the opinion of the court:\nAppellant, M. R. Storm, as county treasurer and ex-officio county collector of Shelb)^ county, filed his application in the county court of that county for judgment against the lands of appellee for alleged delinquent taxes for the year 1926. Appellee filed its objections to an item in the county tax levy for \u201cbridges under county aid construction and right of way, $40,000,\u201d by reason of which a tax of $575.37 was levied against appellee\u2019s property. The county court rendered judgment sustaining appellee\u2019s objections to this tax, from which judgment appellant has appealed to this court.\nAppellee\u2019s objection to this item was, that it levied taxes for two distinct purposes without specifying the amount levied for such purposes separately. Section 121 of the Revenue act expressly provides that when county taxes are levied for several purposes the amount for each purpose shall be stated separately. This provision is mandatory. Bridges and rights of way are in common parlance entirely different objects. Words found in a tax levy are to be taken in their ordinary acceptation unless there is something in the context or subject matter which would cause them to have a different meaning.\nAppellant\u2019s contention is that this levy was made for the single purpose of county aid bridge improvements and could be spent for anything connected therewith, either a bridge or a right of way upon which to set the bridge; that but one purpose is expressed by the wording of this proposed levy, and that is, to build bridges under county aid construction; that \u201cthere is nothing else that is certain or that is further expressed that any living person can say is a purpose of a levy unless words are added that do not appear in the declared purpose of the proposed levy item. The simple words \u2018right of way\u2019 mean nothing, standing alone. To make them a purpose of levy there would have to be added to them \u2018for highways,\u2019 or \u2018for bridges,\u2019 or for something that uses a right of way, and as to this the item objected to is silent;\u201d that there are \u201csome twenty things that have and use a right of way, and \u2018bridges under county aid construction\u2019 is one of them.\u201d These arguments only tend to make clearer that this levy is void for uncertainty by reason of the failure to itemize it.\nThe county court did not err in its judgment, and it is affirmed.\n, Judgment affirmed.",
        "type": "majority",
        "author": "Mr. Chief Justice Heard"
      }
    ],
    "attorneys": [
      "Robert I. Pugh, for appellant.",
      "H. T. Dick, and W. L. Kelley, for appellee."
    ],
    "corrections": "",
    "head_matter": "(No. 18542.\nThe People ex rel. M. R. Storm, County Collector, Appellant, vs. The Eastern Illinois and St. Louis Railroad Company, Appellee.\nOpinion filed December 21, 1927.\nRobert I. Pugh, for appellant.\nH. T. Dick, and W. L. Kelley, for appellee."
  },
  "file_name": "0177-01",
  "first_page_order": 177,
  "last_page_order": 178
}