Arkansas v. Farm Credit Services of Central Arkansas et al. (520 U.S. 821)

U.S. Supreme Court · decided June 2, 1997 · Supreme Court Database (Spaeth)

Citation
520 U.S. 821 · 117 S. Ct. 1776
Decided
June 2, 1997
Term
October Term 1996
Vote
9–0
Majority author
Justice Kennedy
Issue area
Judicial Power
Disposition
Reversed
Outcome
Petitioning party won
Ideological direction
Conservative

Opinion excerpt

Justice Kennedy delivered the opinion of the Court. The Tax Injunction Act, 28 U. S. C. § 1341, restricts the power of federal district courts to prevent collection or enforcement of state taxes. It states: “The 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.” The statute, on its face, yields no exception to the jurisdictional bar save where the state remedy is wanting, but at least one other exception is established by our cases: The statute does not constrain the power of federal courts if the Umted States sues to protect itself or its instrumentalities from state taxation. Department of Employment v. United States, 385 U. S. 355, 358 (1966). The present case explores the limits of this judicial exception. We decide here whether instrumentalities called Production Credit Associations, corporations chartered under federal law, are included within the exception when they sue by themselves. We hold they are not and so may not sue in federal court for an injunction against state taxation without the United States as co-plaintiff. The action must be dismissed, and, as a result, we do not reach the merits of the taxation dispute. I Production Credit Associations (PCAs) are corporations chartered by the Farm Credit Administration…

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