Franchise Tax Board of California v. United States Postal Service (467 U.S. 512)
U.S. Supreme Court · decided June 11, 1984 · Supreme Court Database (Spaeth)
- Citation
- 467 U.S. 512 · 104 S. Ct. 2549
- Decided
- June 11, 1984
- Term
- October Term 1983
- Vote
- 9–0
- Majority author
- Justice Stevens
- Issue area
- Federalism
- Disposition
- Reversed and remanded
- Outcome
- Petitioning party won
- Ideological direction
- Conservative
Opinion excerpt
Justice Stevens delivered the opinion of the Court. Appellant, the Franchise Tax Board of California, determined that four employees of appellee United States Postal Service were delinquent in the payment of their state income taxes. The Board served process on the Postal Service directing it to withhold the amounts of the delinquencies from the employees’ wages, pursuant to § 18817 of the California Revenue and Taxation Code, which authorizes the Board to require any employer to withhold delinquent taxes from an employee’s salary and transfer those funds to the Board. The question presented is whether the Postal Service was obligated to honor these “orders to withhold.” I — I When the Postal Service refused to comply with the four orders to withhold, the Board filed this action in the United States District Court for the Central District of California asserting that the Service was liable under the Revenue and Taxation Code for failing to honor the orders, and invoking federal jurisdiction pursuant to 39 U. S. C. § 409(a) and 28 U. S. C. § 1339. The District Court entered summary judgment for the Postal Service. It held that 5 U. S. C. §5517, which authorized the agreement that California and the United States had made regarding the withholding of state income taxes from the pay of federal employees, applies only to withholding of anticipated tax liabilities and not to…
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