Cases by Issue - Miscellaneous Conflict

California Franchise Tax Board v. Hyatt

Mon, 05 Jan 2009 17:47:54 +0000

Case Basics

Docket No.

02-42

Petitioner

California Franchise Tax Board

Petitioner Type

Petitioner

Respondent

Hyatt

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

538 U.S. 488 (2003)

Argued

Monday, February 24, 2003

Decided

Wednesday, April 23, 2003

Advocates

H. Bartow Farr, III (Argued the cause for the respondent)

Felix Leatherwood (Los Angeles, California, argued the cause for the petitioner)

Facts of the Case

Gilbert Hyatt filed a part-year resident income-tax return in California for 1991, which represented that he had become a Nevada resident in October 1991, shortly before he received substantial licensing fees. The California Franchise Tax Board (CFTB) determined that Hyatt was a California resident until April 1992 and issued notices of proposed assessments and imposed substantial civil fraud penalties. Hyatt filed suit against CFTB in a Nevada state court, alleging that CFTB had committed negligence and intentional torts during the course of its audit. CFTB argued that the state court lacked subject matter jurisdiction because full faith and credit required that the court apply California law immunizing CFTB from suit. Ultimately, the Nevada Supreme Court allowed the intentional tort claims to proceed to trial. The court held that affording CFTB statutory immunity with respect to intentional torts would contravene Nevada's interest in protecting its citizens from injurious intentional torts and bad faith acts committed by sister States' government employees.

Question

Does the Nevada Supreme Court's refusal to extend full faith and credit to California's statute immunizing its tax collection agency from suit violate the Full Faith and Credit Clause of the Constitution?

Conclusion

Decision: 9 votes for Hyatt, 0 vote(s) against
Legal provision: Article 4, Section 1: Full Faith and Credit Clause

No. In a unanimous opinion delivered by Justice Sandra Day O'Connor, the court held that the Full Faith and Credit Clause does not require Nevada to give full faith and credit to California's statutes providing its tax agency with immunity from suit. Noting that Nevada did not grant immunity to its agencies for intentional torts, the Court reasoned that Nevada's interest in redressing intentional tortious conduct was sufficient to decline to accord full faith and credit to California's immunity of its tax agency to bar intentional tort claims. Accordingly, the Court refused to adopt a new rule mandating that a state court extend full faith and credit to a sister State's statutorily recaptured sovereign immunity from suit when a refusal to do so would interfere with the State's capacity to fulfill its own sovereign responsibilities.

Baker v. General Motors Corp.

Mon, 05 Jan 2009 16:15:11 +0000

Case Basics

Docket No.

96-653

Petitioner

Baker

Petitioner Type

Petitioner

Respondent

General Motors Corp.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

522 U.S. 222 (1998)

Argued

Wednesday, October 15, 1997

Decided

Tuesday, January 13, 1998

Advocates

Paul T. Cappuccio (Argued the cause for the respondent)

Laurence H. Tribe (Argued the cause for the petitioners)

Facts of the Case

After working for General Motors Corporation (GM) for fifteen years as a vehicular fire analyst, Ronald Elwell sued GM for wrongful discharge. In an eventual settlement agreement reached in a Michigan county court, the parties agreed to a permanent injunction barring Elwell from testifying against GM without its consent, unless subpoenaed to do so by another court or tribunal. Thereafter, when Kenneth Lee Baker commenced a product liability action against GM in a Missouri county court, Elwell was subpoenaed to testify on Baker's behalf. When GM argued that Elwell was barred from testifying under the Michigan court injunction, the Missouri court disagreed and permitted his deposition and testimony. After suffering an adverse verdict in the Baker case, GM appealed on the basis that Elwell's testimony was illegally admitted. When a federal appeals court agreed with GM, Baker appealed and the Supreme Court granted certiorari.

Question

Was a Missouri county court's admission of a witness's testimony, barred by a Michigan county court's injunction, a violation of the Full Faith and Credit Clause of Article IV?

Conclusion

Decision: 9 votes for Baker, 0 vote(s) against
Legal provision: Article 4, Section 1: Full Faith and Credit Clause

No. In unanimous decision, the Court held that GM's injunctive agreement with Elwell did not reach beyond the parties specific controversy to affect Elwell's conduct in other states. Noting Missouri's "public policy," shielding from disclosure only confidential or privileged information, the Court reasoned that since Elwell's testimony in the Baker case was neither confidential nor privileged, its prohibition would not be necessary. Finally, the Court ruled that full faith and credit does not require states to adopt other state's practices regarding time, manner, and mechanisms for enforcing judgments. Such enforcement measures are subject to the "even-handed" control of local state forums.

Simons v. Miami Beach Nat. Bank

Mon, 05 Jan 2009 17:34:16 +0000

Case Basics

Docket No.

363

Petitioner

Simons

Petitioner Type

Petitioner

Respondent

Miami Beach Nat. Bank

Respondent Type

Respondent

Heard By

Warren Court (1962-1965)

Decided By

Warren Court (1962-1965)

Opinion

381 U.S. 81 (1965)

Argued

Wednesday, March 10, 1965

Decided

Monday, May 3, 1965

Facts of the Case

None

Question

None

Conclusion

Decision: 7 votes for Miami Beach Nat. Bank, 0 vote(s) against
Legal provision: Article 4, Section 1: Full Faith and Credit Clause

None

Aldrich v. Aldrich

Mon, 05 Jan 2009 17:37:37 +0000

Case Basics

Docket No.

Petitioner

Aldrich

Petitioner Type

Petitioner

Respondent

Aldrich

Respondent Type

Respondent

Heard By

Warren Court (1962-1965)

Decided By

Warren Court (1962-1965)

Opinion

378 U.S. 540 (1964)

Argued

Thursday, October 24, 1963

Decided

Monday, June 22, 1964

Facts of the Case

None

Question

None

Conclusion

Decision: 9 votes for Aldrich, 0 vote(s) against
Legal provision: Article 4, Section 1: Full Faith and Credit Clause

None

Armstrong v. Armstrong

Mon, 05 Jan 2009 16:25:28 +0000

Case Basics

Docket No.

Petitioner

Armstrong

Petitioner Type

Petitioner

Respondent

Armstrong

Respondent Type

Respondent

Heard By

Warren Court (1955-1956)

Decided By

Warren Court (1955-1956)

Opinion

350 U.S. 568 (1956)

Argued

Tuesday, November 15, 1955

Decided

Monday, April 9, 1956

Facts of the Case

None

Question

None

Conclusion

Decision: 9 votes for Armstrong, 0 vote(s) against
Legal provision: Article 4, Section 1: Full Faith and Credit Clause

None