Blinn v. Nelson

222 U.S. 1 · Supreme Court of the United States · 1911

Facts

Mabel E. Allen disappeared from Massachusetts to parts unknown "within or prior to the year 1892," leaving no known agent in the state. She held an interest in property derived from the residuary clause of Jonathan Merry's will, which was proved in 1828. In or about 1899, an administrator collected funds from French Spoliation Claims, and Mabel Allen's share amounted to $1633 and $22, plus accumulated interest, forming the fund in controversy.

Procedural history

The Probate Court issued a decree of distribution, which was subsequently affirmed by the Supreme Judicial Court of the Commonwealth. The receiver, challenging the constitutionality of the Massachusetts statutes under the Fourteenth Amendment, then brought the case to this court.

Issue

The legal question is whether Massachusetts Revised Laws, c. 144, §§ 10, 11, and 12, which allow for the distribution of an absentee's property after a period that could be as short as one year after a receiver's appointment, violate the Fourteenth Amendment due to insufficient notice or an arbitrary and unreasonable time limit.

Holding

The Court held that the Massachusetts statute is constitutional and affirmed the lower court's decree of distribution. It found that the statute's provisions for barring an absentee's title and distributing property do not violate the Fourteenth Amendment.

Rule

A state legislature acts within its constitutional discretion when establishing a statute of limitations for property recovery, even if the period is relatively short (e.g., one year), especially when the property owner has been unheard of for a long time (e.g., fourteen years) and is presumed dead. The court reasoned that constitutional law must accept some risk of extraordinary cases, and in the vast majority of instances, justice will be served. The statute included reasonably careful provisions for notice by publication and initial seizure of property, which further supported its constitutionality.

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