Grable & Sons Metal Products, Inc. v. Darue Engineering & Manufacturing (545 U.S. 308)
U.S. Supreme Court · decided June 13, 2005 · Supreme Court Database (Spaeth)
- Citation
- 545 U.S. 308 · 125 S. Ct. 2363
- Decided
- June 13, 2005
- Term
- October Term 2004
- Vote
- 9–0
- Majority author
- Justice Souter
- Issue area
- Judicial Power
- Disposition
- Affirmed
- Outcome
- Petitioning party lost
- Ideological direction
- Liberal
Opinion excerpt
Justice Souter delivered the opinion of the Court. The question is whether want of a federal cause of action to try claims of title to land obtained at a federal tax sale precludes removal to federal court of a state action with nondiverse parties raising a disputed issue of federal title law. We answer no, and hold that the national interest in providing a federal forum for federal tax litigation is sufficiently substantial to support the exercise of federal-question jurisdiction over the disputed issue on removal, which would not distort any division of labor between the state and federal courts, provided or assumed by Congress. h-H In 1994, the Internal Revenue Service seized Michigan real property belonging to petitioner Grable & Sons Metal Products, Inc., to satisfy Grable’s federal tax delinquency. Title 26 U. S. C. § 6335 required the IRS to give notice of the seizure, and there is no dispute that Grable received actual notice by certified mail before the IRS sold the property to respondent Darue Engineering & Manufacturing. Although Grable also received notice of the sale itself, it did not exercise its statutory right to redeem the property within 180 days of the sale, § 6337(b)(1), and after that period had passed, the Government gave Darue a quitclaim deed, §6339. Five years later, Grable brought a quiet title action in state court, claiming that Darue’s record…
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