Ala. Dep't of Revenue v. CSX Transp., Inc. (575 U.S. 21)
U.S. Supreme Court · decided March 4, 2015 · Supreme Court Database (Spaeth)
- Citation
- 575 U.S. 21 · 135 S. Ct. 1136
- Decided
- March 4, 2015
- Term
- October Term 2014
- Vote
- 7–2
- Majority author
- Justice Scalia
- Issue area
- Economic Activity
- Disposition
- Reversed and remanded
- Outcome
- Petitioning party won
- Ideological direction
- Liberal
Opinion excerpt
Justice SCALIAdelivered the opinion of the Court. Federal law prohibits States from imposing taxes that "discriminat[e] against a rail carrier." 49 U.S.C. § 11501(b)(4). We are asked to decide whether a State violates this prohibition by taxing diesel fuel purchases made by a rail carrier while exempting similar purchases made by its competitors; and if so, whether the violation is eliminated when other tax provisions offset the challenged treatment of railroads. I Alabama taxes businesses and individuals for the purchase or use of personal property. Ala.Code §§ 40-23-2(1), 40-23-61(a) (2011). Alabama law sets the general tax rate at 4% of the value of the property purchased or used. Ibid. The State applies the tax, at the usual 4% rate, to railroads' purchase or use of diesel fuel for their rail operations. But it exempts from the tax purchases and uses of diesel fuel made by trucking transport companies (whom we will call motor carriers) and companies that transport goods interstate through navigable waters (water carriers). Motor carriers instead pay a 19-cent-per-gallon fuel-excise tax on diesel; water carriers pay neither the sales nor fuel-excise tax on their diesel. § 40-17-325(a)(2), and (b); § 40-23-4(a)(10) (2014 Cum. Supp.). The parties stipulate that rail carriers, motor carriers, and water carriers compete. Respondent CSX Transportation, a rail carrier operating…
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