Franchise Tax Board of California v. Construction Laborers Vacation Trust for Southern California et al. (463 U.S. 1)
U.S. Supreme Court · decided June 24, 1983 · Supreme Court Database (Spaeth)
- Citation
- 463 U.S. 1 · 103 S. Ct. 2841
- Decided
- June 24, 1983
- Term
- October Term 1982
- Vote
- 9–0
- Majority author
- Justice Brennan
- Issue area
- Judicial Power
- Disposition
- Vacated and remanded
- Outcome
- Petitioning party won
- Ideological direction
- Conservative
Opinion excerpt
Justice Brennan delivered the opinion of the Court. The principal question in dispute between the parties is whether the Employee Retirement Income Security Act of 1974 (ERISA), 88 Stat. 829, as amended, 29 U. S. C. § 1001 et seq. (1976 ed. and Supp. V), permits state tax authorities to collect unpaid state income taxes by levying on funds held in trust for the taxpayers under an ERISA-covered vacation benefit plan. The issue is an important one, which affects thousands of federally regulated trusts and all nonfederal tax collection systems, and it must eventually receive a definitive, uniform resolution. Nevertheless, for reasons involving perhaps more history than logic, we hold that the lower federal courts had no jurisdiction to decide the question in the case before us, and we vacate the judgment and remand the case with instructions to remand it to the state court from which it was removed. I None of the relevant facts is in dispute. Appellee Construction Laborers Vacation Trust for Southern California (CLVT) is a trust established by an agreement between four associations of employers active in the construction industry in southern California and the Southern California District Council of Laborers, an arm of the District Council and affiliated locals of the Laborers’ International Union of North America. The purpose of the agreement and trust was to establish a…
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