National Private Truck Council, Inc. v. Oklahoma Tax Comm'n
515 U.S. 582 (1995)

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OCTOBER TERM, 1994

Syllabus

NATIONAL PRIVATE TRUCK COUNCIL, INC., ET AL. v. OKLAHOMA TAX COMMISSION ET AL.

CERTIORARI TO THE SUPREME COURT OF OKLAHOMA No. 94-688. Argued April 18, 1995-Decided June 19, 1995

In the Oklahoma state courts, petitioners successfully challenged certain state taxes as violating the "dormant" Commerce Clause. The Oklahoma Supreme Court ordered respondents to award refunds pursuant to state law, but declined to award declaratory or injunctive relief under 42 U. S. C. § 1983 or attorney's fees under § 1988. The court reasoned that because adequate remedies existed under state law, the Tax Injunction Act would have precluded petitioners from seeking an injunction in federal court; although that Act does not apply to state courts, the Oklahoma Supreme Court invoked the principle of "intrastate uniformity" to conclude that petitioners were not entitled to injunctive or declaratory relief under § 1983.

Held:

1. Section 1983 provides no basis for courts to issue injunctive or declaratory relief in state tax cases when there is an adequate remedy at law. This Court has long held that courts should adopt a hands-off approach with respect to state tax administration. Dows v. Chicago, 11 Wall. 108, 110. In passing § 1983, Congress did not limit this strong background principle of noninterference with state taxation. Construing § 1983 with this principle in mind, the Court concludes that § 1983 does not call for courts-whether federal or state-to disrupt state tax administration by issuing injunctive or declaratory relief when state law furnishes an adequate legal remedy. Pp. 588-592.

2. Since no relief could be awarded under § 1983, no attorney's fees can be awarded under § 1988. P. 592.

879 P. 2d 137, affirmed.

THOMAS, J., delivered the opinion for a unanimous Court. KENNEDY, J., filed a concurring opinion, post, p. 592.

Richard A. Allen argued the cause for petitioners. With him on the briefs was Richard P. Schweitzer.

Stanley P. Johnston argued the cause for respondents.

With him on the brief was Robert B. Struble. *

*Briefs of amici curiae urging reversal were filed for the Direct Marketing Association, Inc., by George S. Isaacson, Martin I. Eisenstein, and


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JUSTICE THOMAS delivered the opinion of the Court.

In the Oklahoma state courts, petitioners successfully challenged certain Oklahoma taxes as violating the "dormant" Commerce Clause. Although the Oklahoma Supreme Court ordered respondents to award refunds pursuant to

Robert J. Levering; for the National Retail Federation by Timothy B. Dyk, Maryann B. Gall, and Jeffrey S. Sutton; and for the Washington Legal Foundation et al. by Daniel J. Popeo and Richard A. Samp.

Briefs of amici curiae urging affirmance were filed for the State of New Jersey et al. by Deborah T. Poritz, Attorney General of New Jersey, Joseph L. Yannotti, Assistant Attorney General, Rachel J. Horowitz, Deputy Attorney General, Jeff Sessions, Attorney General of Alabama, Grant Woods, Attorney General of Arizona, Winston Bryant, Attorney General of Arkansas, Daniel E. Lungren, Attorney General of California, Richard Blumenthal, Attorney General of Connecticut, M. Jane Brady, Attorney General of Delaware, Garland Pinkston, Jr., Acting Corporation Counsel of the District of Columbia, Robert A. Butterworth, Attorney General of Florida, Michael J. Bowers, Attorney General of Georgia, Margery S. Bronster, Attorney General of Hawaii, Alan G. Lance, Attorney General of Idaho, Jim Ryan, Attorney General of Illinois, Pamela Fanning Carter, Attorney General of Indiana, Carla J. Stovall, Attorney General of Kansas, Chris Gorman, Attorney General of Kentucky, Andrew Ketterer, Attorney General of Maine, J. Joseph Curran, Jr., Attorney General of Maryland, Scott Harshbarger, Attorney General of Massachusetts, Frank J. Kelley, Attorney General of Michigan, Hubert H. Humphrey III, Attorney General of Minnesota, Mike Moore, Attorney General of Mississippi, Joseph P. Mazurek, Attorney General of Montana, Don Stenberg, Attorney General of Nebraska, Frankie Sue Del Papa, Attorney General of Nevada, Jeffrey R. Howard, Attorney General of New Hampshire, Tom Udall, Attorney General of New Mexico, Michael F. Easley, Attorney General of North Carolina, Heidi Heitkamp, Attorney General of North Dakota, Betty D. Montgomery, Attorney General of Ohio, Theodore R. Kulongoski, Attorney General of Oregon, Ernest D. Preate, Jr., Attorney General of Pennsylvania, Pedro R. Pierluisi, Attorney General of Puerto Rico, Jeffrey B. Pine, Attorney General of Rhode Island, Charles W Burson, Attorney General of Tennessee, Dan Morales, Attorney General of Texas, Jan Graham, Attorney General of Utah, Jeffrey L. Amestoy, Attorney General of Vermont, James S. Gilmore III, Attorney General of Virginia, Christine O. Gregoire, Attorney General of Washington, James E. Doyle, Attorney General of Wisconsin, and Eleni M. Constantine; for the Boyertown Area School District et al. by Howard J. Bashman; and for the National Conference of State Legislatures et al. by Richard Ruda and James I. Crowley.


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Full Text of Opinion

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