Rockford Life Insurance Co. v. Illinois Department of Revenue et al. (482 U.S. 182)
U.S. Supreme Court · decided June 8, 1987 · Supreme Court Database (Spaeth)
- Citation
- 482 U.S. 182 · 107 S. Ct. 2312
- Decided
- June 8, 1987
- Term
- October Term 1986
- Vote
- 9–0
- Majority author
- Justice Stevens
- Issue area
- Economic Activity
- Disposition
- Affirmed
- Outcome
- Petitioning party lost
- Ideological direction
- Liberal
Opinion excerpt
Justice Stevens delivered the opinion of the Court. This case involves financial instruments commonly known as “Ginnie Maes.” These instruments are issued by private financial institutions, which are obliged to make timely payment of the principal and interest as set forth in the certificates. The Government National Mortgage Association (GNMA) guarantees that the payments will be made as scheduled. The question presented today is whether these instruments are exempt from state taxation under the constitutional principle of intergovernmental tax immunity, or under the relevant immunity statute. Prior to 1979 changes in Illinois’ tax law, Rockford Life Insurance Company (Rockford) paid an annual property tax on the assessed value of its capital stock. In 1978, the Illinois taxing authorities included the value of Rockford’s portfolio of Ginnie Maes in their calculation of the corporation’s net assets. Rockford challenged the assessment in the Illinois courts and the County Treasurer filed an action to collect the full amount of the assessment ($723,053.70). The Illinois courts uniformly rejected Rockford’s contention that the securities were exempt from state property taxes, reasoning that “the securities in question here were not ‘other obligations of the United States’ within the meaning of § 3701,” and that the constitutional and statutory inquiries were identical in this…
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