United States v. New Mexico et al. (455 U.S. 720)
U.S. Supreme Court · decided March 24, 1982 · Supreme Court Database (Spaeth)
- Citation
- 455 U.S. 720 · 102 S. Ct. 1373
- Decided
- March 24, 1982
- Term
- October Term 1981
- Vote
- 9–0
- Majority author
- Justice Blackmun
- Issue area
- Economic Activity
- Disposition
- Affirmed
- Outcome
- Petitioning party lost
- Ideological direction
- Liberal
Opinion excerpt
Justice Blackmun delivered the opinion of the Court. We are presented here with a recurring problem: to what extent may a State impose taxes on contractors that conduct business with the Federal Government? HH A This case concerns the contractual relationships between three private entities and the United States. The three agreements involved are typical in most respects of management contracts devised by the Atomic Energy Commission (AEC), now the Department of Energy (DOE). Like many of the Government’s contractual undertakings, DOE management contracts generally provide the private contractor with its costs plus a fixed fee. But in several ways DOE agreements are a unique species of contract, designed to facilitate long-term private management of Government-owned research and development facilities. As the parties to this case acknowledge, the complex and intricate contractual provisions make it virtually impossible to describe the contractual relationship in standard agency terms. See App. 196-197; Hiestand & Florsheim, The AEC Management Contract Concept, 29 Federal B. J. 67 (1969) (Hiestand & Florsheim). While subject to the general direction of the Government, the contractors are vested with substantial autonomy in their operations and procurement practices. The first of the contractors, Sandia Corporation, was organized in 1949 as a subsidiary of Western Electric…
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