California Franchise Tax Board v. Hyatt (578 U.S. 171)

U.S. Supreme Court · decided April 19, 2016 · Supreme Court Database (Spaeth)

Citation
578 U.S. 171 · 136 S. Ct. 1277
Decided
April 19, 2016
Term
October Term 2015
Vote
6–2
Majority author
Justice Breyer
Issue area
Economic Activity
Disposition
Vacated and remanded
Outcome
Petitioning party won
Ideological direction
Conservative

Opinion excerpt

Justice BREYERdelivered the opinion of the Court. In Nevada v. Hall, 440 U.S. 410, 99 S.Ct. 1182, 59 L.Ed.2d 416 (1979), this Court held that one State (here, Nevada) can open the doors of its courts to a private citizen's lawsuit against another State (here, California) without the other State's consent. In this case, a private citizen, a resident of Nevada, has brought a suit in Nevada's courts against the Franchise Tax Board of California, an agency of the State of California. The board has asked us to overrule Hall and hold that the Nevada courts lack jurisdiction to hear this lawsuit. The Court is equally divided on this question, and we consequently affirm the Nevada courts' exercise of jurisdiction over California. See, e.g., Exxon Shipping Co. v. Baker, 554 U.S. 471, 484, 128 S.Ct. 2605, 171 L.Ed.2d 570 (2008)(citing Durant v. Essex Co., 7 Wall. 107, 112, 19 L.Ed. 154 (1869)). California also asks us to reverse the Nevada court's decision insofar as it awards the private citizen greater damages than Nevada law would permit a private citizen to obtain in a similar suit against Nevada's own agencies. We agree that Nevada's application of its damages law in this case reflects a special, and constitutionally forbidden, " 'policy of hostility to the public Acts' of a sister State," namely, California. U.S. Const., Art. IV, § 1(Full Faith and Credit Clause); Franchise Tax…

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