Forum
U.S. Supreme Court
Case Status
Decided
Docket Number
Term
2014 Term
Oral Argument Date
December 08, 2014
Lower Court Opinion
Questions Presented
Whether the Tax Injunction Act, which provides that “[t]he district courts shall not enjoin, suspend or restrain the assessment, levy or collection of any tax under State law where a plain, speedy and efficient remedy may be had in the courts of such State,” bars federal court jurisdiction over a suit brought by non-taxpayers to enjoin the informational notice and reporting requirements of a state law that neither imposes a tax, nor requires the collection of a tax, but serves only as a secondary aspect of state tax administration.
Case Updates
Supreme Court overturns jurisdictional bar in certain state tax cases
March 03, 2015
The Court rejected Colorado’s argument that federal courts are barred from hearing challenges to state laws if the result could indirectly affect the collection of state taxes.
U.S. Chamber files amicus brief
September 16, 2014
In its brief, the U.S. Chamber asked the Supreme Court to overturn a Tenth Circuit ruling that the Tax Injunction Act (“TIA”) bars federal courts from exercising jurisdiction over any lawsuit that challenges a state’s methods of administrating its tax laws and generating revenue. The Chamber argued that since plaintiffs are not state taxpayers, are not challenging state authority to collect tax and are suing for relief unrelated to tax liability to the state, that federal courts’ jurisdiction should not be barred in cases like Brohl brought in the federal courts. The Chamber further argued that the Act’s original intent was to prevent lawsuits brought by taxpayers intent on avoiding paying their tax bill and that the jurisdictional bar only applies when a state taxpayer seeks a federal-court order that would decrease the amount of taxes the taxpayer owes to the state.
Case Documents
- Cert. Petition -- Direct Marketing Association v. Brohl (U.S. Supreme Court).pdf
- Council on State Taxation Amicus Brief -- Direct Marketing Association v. Brohl (U.S. Supreme Court).pdf
- Brief in Opposition -- Direct Marketing Association v. Brohl (U.S. Supreme Court).pdf
- Reply Brief -- Direct Marketing Association v. Brohl (U.S. Supreme Court).pdf
- Brief for Petitioner -- Direct Marketing Association v. Brohl (U.S. Supreme Court).pdf
- Tax Professionals Amicus Brief -- Direct Marketing Association v. Brohl (U.S. Supreme Court).pdf
- Tax Foundation Amicus Brief -- Direct Marketing Association v. Brohl (U.S. Supreme Court).pdf
- U.S. Chamber Amicus Brief -- Direct Marketing Association v. Brohl (U.S. Supreme Court).pdf
- Council on State Taxation Amicus Brief -- Direct Marketing Association v. Brohl (U.S. Supreme Court)_0.pdf
- NFIB, et al. Amicus Brief -- Direct Marketing Association v. Brohl (U.S. Supreme Court).pdf
- Respondent's Brief -- Direct Marketing Association v. Brohl (U.S. Supreme Court).pdf
- National Governors Association Amici Brief -- Direct Marketing Association v. Brohl (U.S. Supreme Court).pdf
- States of Illinois, et al. Amici Brief -- Direct Marketing Association v. Brohl (U.S. Supreme Court).pdf
- Multistate Tax Commission Amicus Brief --Direct Marketing Association v. Brohl (U.S. Supreme Court).pdf
- Interested Law Professors Amici Brief -- Direct Marketing Association v. Brohl (U.S. Supreme Court).pdf
- Petitioner Reply Brief -- Direct Marketing Association v. Brohl (U.S. Supreme Court).pdf
- Opinion -- Direct Marketing Association v. Brohl (U.S. Supreme Court).pdf