Henry Harper, et al. v. Virginia Department of Taxation (509 U.S. 86)
U.S. Supreme Court · decided June 18, 1993 · Supreme Court Database (Spaeth)
- Citation
- 509 U.S. 86 · 113 S. Ct. 2510
- Decided
- June 18, 1993
- Term
- October Term 1992
- Vote
- 7–2
- Majority author
- Justice Thomas
- Issue area
- Federalism
- Disposition
- Reversed and remanded
- Outcome
- Petitioning party won
- Ideological direction
- Liberal
Opinion excerpt
Justice Thomas delivered the opinion of the Court. In Davis v. Michigan Dept. of Treasury, 489 U. S. 803 (1989), we held that a State violates the constitutional doctrine of intergovernmental tax immunity when it taxes retirement benefits paid by the Federal Government but exempts from taxation all retirement benefits paid by the State or its political subdivisions. Relying on the retroactivity analysis of Chevron Oil Co. v. Huson, 404 U. S. 97 (1971), the Supreme Court of Virginia twice refused to apply Davis to taxes imposed before Davis was decided. In accord with Griffith v. Kentucky, 479 U. S. 314 (1987), and James B. Beam Distilling Co. v. Georgia, 501 U. S. 529 (1991), we hold that this Court’s application of a rule of federal law to the parties before the Court requires every court to give retroactive effect to that decision. We therefore reverse. I The Michigan tax scheme at issue in Davis “exempted] from taxation all retirement benefits paid by the State or its political subdivisions, but leviefd] an income tax on retirement benefits paid by . . . the Federal Government.” 489 U. S., at 805. We held that the United States had not consented under 4 U. S. C. § 111 to this discriminatory imposition of a heavier tax burden on federal benefits than on state and local benefits. 489 U. S., at 808-817. Because Michigan “conceded that a refund [was] appropriate,” we…
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