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- NOTICE: This opinion is subject to formal revision before publication in the
- preliminary print of the United States Reports. Readers are requested to
- notify the Reporter of Decisions, Supreme Court of the United States, Wash-
- ington, D.C. 20543, of any typographical or other formal errors, in order that
- corrections may be made before the preliminary print goes to press.
- SUPREME COURT OF THE UNITED STATES
- --------
- No. 91-1353
- --------
- THOMAS F. CONROY, PETITIONER v. WALTER
- ANISKOFF, Jr., et al.
- on writ of certiorari to the supreme judicial
- court of maine
- [March 31, 1993]
-
- Justice Stevens delivered the opinion of the Court.
- The Soldiers' and Sailors' Civil Relief Act of 1940, 54
- Stat. 1178, as amended, 50 U. S. C. App. 501 et seq.
- (Act), suspends various civil liabilities of persons in
- military service. At issue in this case is the provision in
- 525 that the -period of military service shall not be
- included in computing any period . . . provided by any law
- for the redemption of real property sold or forfeited to
- enforce any obligation, tax, or assessment.- The question
- presented is whether a member of the Armed Services
- must show that his military service prejudiced his ability
- to redeem title to property before he can qualify for the
- statutory suspension of time.
-
- I
- Petitioner is an officer in the United States Army. He
- was on active duty continuously from 1966 until the time
- of trial. In 1973 he purchased a parcel of vacant land in
- the town of Danforth, Maine. He paid taxes on the
- property for 10 years, but failed to pay the 1984, 1985,
- and 1986 local real estate taxes. In 1986, following the
- Maine statutory procedures that authorize it to acquire
- tax-delinquent real estate, the town sold the property.
- In 1987 petitioner brought suit in the Maine District
- Court against the town and the two purchasers. He
- claimed that 525 of the Act tolled the redemption period
- while he was in military service, and federal law therefore
- prevented the town from acquiring good title to the
- property even though the State's statutory procedures had
- been followed. The trial court rejected the claim. In an
- unreported opinion, it noted that some courts had con-
- strued 525 literally, but it elected to follow a line of
-
-
- decisions that refused to toll the redemption period unless
- the taxpayer could show that -military service resulted in
- hardship excusing timely legal action.- It agreed with
- those courts that it would be -absurd and illogical- to toll
- limitations periods for career service personnel who had
- not been -handicapped by their military status.- The
- Supreme Judicial Court of Maine affirmed by an equally
- divided court. We granted certiorari to resolve the
- conflict in the interpretation of 525. 505 U. S. ___
- (1992).
- II
- The statutory command in 525 is unambiguous, un-
- equivocal, and unlimited. It states that the period of
- military service -shall not be included- in the computation
- of -any period now or hereafter provided by any law for
- the redemption of real property . . . .- Respondents do
- not dispute the plain meaning of this text. Rather, they
- argue that when 525 is read in the context of the entire
- statute, it implicitly conditions its protection on a demon-
- stration of hardship or prejudice resulting from military
- service. They make three points in support of this
- argument: that the history of the Act reveals an intent to
- provide protection only to those whose lives have been
- temporarily disrupted by military service; that other
- provisions of the Act are expressly conditioned on a
- showing of prejudice; and that a literal interpretation
- produces illogical and absurd results. Neither separately
- nor in combination do these points justify a departure
- from the unambiguous statutory text.
- Respondents correctly describe the immediate cause for
- the statute's enactment in 1940, the year before our entry
- into World War II. Congress stated its purpose to -expe-
- dite the national defense under the emergent conditions
- which are threatening the peace and security of the
- United States . . . .- 50 U. S. C. App. 510. That purpose
- undoubtedly contemplated the special hardship that
- military duty imposed on those suddenly drafted into
- service by the national emergency. Neither that emer-
- gency, nor a particular legislative interest in easing
- sudden transfers from civilian to military status, however,
- justifies the conclusion that Congress did not intend all
- members of the Armed Forces, including career personnel,
- to receive the Act's protections. Indeed, because Congress
- extended the life of the Act indefinitely in 1948, well
- after the end of World War II, the complete legislative
- history confirms a congressional intent to protect all
- military personnel on active duty, just as the statutory
- language provides.
- Respondents also correctly remind us to -follow the
- cardinal rule that a statute is to be read as a whole, see
- Massachusetts v. Morash, 490 U. S. 107, 115 (1989), since
- the meaning of statutory language, plain or not, depends
- on context.- King v. St. Vincent's Hospital, 502 U. S. ___,
- ___ (1991) (slip op., at 6). But as in King, the context of
- this statute actually supports the conclusion that Congress
- meant what 525 says. Several provisions of the statute
- condition the protection they offer on a showing that
- military service adversely affected the ability to assert or
- protect a legal right. To choose one of many examples,
- 532(2) authorizes a stay of enforcement of secured
- obligations unless -the ability of the defendant to comply
- with the terms of the obligation is not materially affected
- by reason of his military service.- The comprehensive
- character of the entire statute indicates that Congress
- included a prejudice requirement whenever it considered
- it appropriate to do so, and that its omission of any such
- requirement in 525 was deliberate.
- Finally, both the history of this carefully reticulated
- statute, and our history of interpreting it, refute any
- argument that a literal construction of 525 is so absurd
- or illogical that Congress could not have intended it. In
- many respects the 1940 Act was a re-enactment of World
- War I legislation that had, in turn, been modeled after
- legislation that several States adopted during the Civil
- War. See Boone v. Lightner, 319 U. S. 561, 565-569
- (1943). The Court had emphasized the comprehensive
- character and carefully segregated arrangement of the
- various provisions of the World War I statute in Ebert v.
- Poston, 266 U. S. 548, 554 (1925), and it had considered
- the consequences of requiring a showing of prejudice when
- it construed the World War II statute in Boone, supra.
- Since we presume that Congress was familiar with those
- cases, we also assume that Congress considered the
- decision in Ebert to interpret and apply each provision of
- the Act separately when it temporarily re-established the
- law as a whole in 1940, and then considered Boone's
- analysis of a prejudice requirement when it permanently
- extended the Act in 1948.
- Legislative history confirms that assumption. Since the
- enactment of the 1918 Act, Congress has expressed its
- understanding that absolute exemptions might save time
- or money for service members only at the cost of injuring
- their own credit, their family's credit, and the domestic
- economy; it presumably required a showing of prejudice
- only when it seemed necessary to confer on the service
- member a genuine benefit. By distinguishing sharply
- between the two types of protections, Congress unquestion-
- ably contemplated the ways that either type of protection
- would affect both military debtors and their civilian
- creditors.
- The long and consistent history and the structure of this
- legislation therefore lead us to conclude that-just as the
- language of 525 suggests-Congress made a deliberate
- policy judgment placing a higher value on firmly protect-
- ing the service member's redemption rights than on
- occasionally burdening the tax collection process. Given
- the limited number of situations in which this precisely
- structured statute offers such absolute protection, we
- cannot say that Congress would have found our straight-
- forward interpretation and application of its words either
- absurd or illogical. If the consequences of that interpre-
- tation had been-or prove to be-as unjust as respondents
- contend, we are confident that Congress would have
- corrected the injustice-or will do so in the future.
- The judgment of the Supreme Judicial Court of Maine
- is reversed.
- It is so ordered.
-