[1][2] The case was filed in 2019 as a class action by attorneys Charles Watkins, Garrett Blanchfield, Vildan Teske, and Roberta Yard.

In 2015, after years of property tax delinquency, Hennepin County seized Tyler's condo, foreclosed on it, and sold it for $40,000.

Lastly, he rejects the county's argument that Tyler had relinquished any interest in the surplus equity in her home due to her failure to pay property taxes.

He states: The principle that a government may not take more from a taxpayer than she owes can trace its origins at least as far back as Runnymeade in 1215, where King John swore in the Magna Carta that when his sheriff or bailiff came to collect any debts owed him from a dead man, they could remove property “until the debt which is evident shall be fully paid to us; and the residue shall be left to the executors to fulfil the will of the deceased.”He cites other cases from English law and American Colonial Law establishing the consensus that the government may not take more than it was owed to satisfy a debt, and states that that consensus "held true through the passage of the Fourteenth Amendment."

Additionally, he says, this consensus remains true at the time of writing, as 36 states and the Federal Government require the excess value to be returned to the taxpayer.

The District Court had ruled that Minnesota's tax-forfeiture scheme was not "punitive" because its primary purpose was to compensate the county for the lost revenue resulting from unpaid taxes.

However, quoting Austin v. United States, Gorsuch counters that the Excessive Fines Clause applies to statutory schemes that serve in part to punish.

The lower court had also argued that the scheme in question could not be punitive since it would confer a windfall on homeowners whose tax bill exceeded the value of the property.

But nor has this Court ever held that a scheme producing fines that punishes some individuals can escape constitutional scrutiny merely because it does not punish others.Lastly, Gorsuch argues against the county's claim that since Minnesota's tax-forfeiture scheme does not condition the loss of surplus equity on a criminal conviction (or even on criminal behavior), it is therefore not punitive.

Quoting United States v. Bajakajian, Gorsuch counters that the Court has said that such a scheme may still be punitive where it serves another “goal of punishment,” such as deterrence, and that the District Court approved the Minnesota tax-forfeiture scheme on the grounds that "the ultimate possibility of loss of property serves as a deterrent to those taxpayers considering tax delinquency".