CSX Transportation, Inc., Petitioner v. Alabama Department of Revenue et al. (562 U.S. 277)
U.S. Supreme Court · decided February 22, 2011 · Supreme Court Database (Spaeth)
- Citation
- 562 U.S. 277 · 131 S. Ct. 1101
- Decided
- February 22, 2011
- Term
- October Term 2010
- Vote
- 7–2
- Majority author
- Justice Kagan
- Issue area
- Economic Activity
- Disposition
- Reversed and remanded
- Outcome
- Petitioning party won
- Ideological direction
- Conservative
Opinion excerpt
Justice Kagan delivered the opinion of the Court. The Railroad Revitalization and Regulatory Reform Act of 1976 restricts the ability of state and local governments to levy discriminatory taxes on rail carriers. We consider here whether a railroad may invoke this statute to challenge sales and use taxes that apply to rail carriers (among others), but exempt their competitors in the transportation industry. We conclude that the railroad may do so. I A Congress enacted the Railroad Revitalization and Regulatory Reform Act of 1976 (Act or 4-R Act) to “restore the financial stability of the railway system of the United States,” among other purposes. § 101(a), 90 Stat. 33. To help achieve this goal, Congress targeted state and local taxation schemes that discriminate against rail carriers. Burlington Northern R. Co. v. Oklahoma Tax Comm’n, 481 U. S. 454, 457 (1987). The provision of the Act at issue here, now codified at 49 U. S. C. § 11501, bars States and localities from engaging in four forms of discriminatory taxation. 90 Stat. 54. Section 11501(b) describes the prohibited practices. It begins with three provisions addressed specifically to property taxes; it concludes with a catch-all provision concerning other taxes. According to § 11501(b), States (or their subdivisions) “may not”: “(1) Assess rail transportation property at a value that has a higher ratio to the true…
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