Meyer v. United States

PETITIONER: Meyer
RESPONDENT: United States
LOCATION: Prince Edward County, VA

DOCKET NO.: 61
DECIDED BY: Warren Court (1962-1965)
LOWER COURT: United States Court of Appeals for the Second Circuit

CITATION: 375 US 233 (1963)
ARGUED: Oct 24, 1963
DECIDED: Dec 16, 1963

Facts of the case

Question

Media for Meyer v. United States

Audio Transcription for Oral Argument - October 24, 1963 in Meyer v. United States

Earl Warren:

Number 61, Ethel Meyer, Petitioner, versus United States.

Mr. Sherman.

Samuel W. Sherman:

Yes, Your Honor, if the Court pleases.

This case is here on a writ of certiorari to the United States Court of Appeals for the Second Circuit.

Ethel Meyer, the petitioner, is the wife of Peter Meyer, deceased.

Peter Meyer, in 1943, had life insurance policies totaling some $50,000.

Under 1943, he borrowed from the Huntington National Bank of Ohio the sum of about $26,000 and made assignments and pledged these life insurance policies upon which his wife was the beneficiary to the bank for these loans which were made to him.

Now, in 1943, Peter Meyer did not owe the United States Government any moneys, any tax moneys at all.

In 1945 and 1946 -- 1946, the tax liabilities for those years arose which were due to the Government of the United States from Peter Meyer.

Now, the Government in 1946 and in 1947 made assessments on those tax moneys some $6100.

And as soon as they made those tax assessments under the Code, United States Code, the tax liens arose.

Now, they were unpaid.

These taxes were unpaid.

In 1955, Peter Meyer died, so that there was due to the Government from his estate some $6100.

The bank having received assignments and pledge of these policies upon his death, the bank received the sum of $26,800 or thereabouts, $26,000, I should say, $26,800, which was due the bank for the loans and that exhausted practically with the exception of some $400, the entire shares surrender value of the policies.

William J. Brennan, Jr.:

(Inaudible)

Samuel W. Sherman:

Yes, Your Honor.

Under the agreement, the bank had the right to collect the money that was due it from all -- from the entire proceeds of the policies.

There's no question about that.

William J. Brennan, Jr.:

Net proceeds?

Samuel W. Sherman:

Net proceeds.

William J. Brennan, Jr.:

(Inaudible)

Samuel W. Sherman:

Yes.

William J. Brennan, Jr.:

(Inaudible)

Samuel W. Sherman:

Yes.

Yes, Your Honor, from the entire amounts.

Now, the widow received her moneys, the balance of the proceeds which would be some $24,000 or $23,000 from the insurance companies.

And the United States Government then brought an action against Ethel Meyer, individually and as executrix of the estate, of Peter Meyer's estate, to collect this $6100.

And the -- the position that counsel for Mrs. Meyer took was that this money is justly due to -- from her estates because it was due from the estate, the husband and the estate owed the money.

However, the courts granted summary judgment against her personally upon the basis that the proceeds that she received were subject to those tax claims.