Cases by Issue - Taxpayer's Suit

DaimlerChrysler Corp. v. Cuno

Mon, 05 Jan 2009 17:45:16 +0000

Case Basics

Docket No.

04-1704

Petitioner

William W. Wilkins, Tax Commissioner for the State of Ohio, et al.

Petitioner Type

Petitioner

Respondent

Charlotte Cuno, et al.

Respondent Type

Respondent

Consolidation

Wilkins v. Cuno, No. 04-1724

Heard By

Roberts Court (2006-2009)

Decided By

Roberts Court (2006-2009)

Opinion

547 U.S. ___ (2006)

Granted

Tuesday, September 27, 2005

Argued

Wednesday, March 1, 2006

Decided

Monday, May 15, 2006

Advocates

Peter Enrich (argued the cause for Respondents)

Douglas R. Cole (argued the cause for Petitioners in No. 04-1724)

Theodore B. Olson (argued the cause for Petitioners in No. 04-1704)

Facts of the Case

As part of Ohio's economic development plan, DaimlerChrysler agreed to expand its operations in Toledo in exchange for tax exemptions and tax credits worth roughly $280 million. Charlotte Cuno and others challenged the deal, however, arguing that Ohio had violated the Commerce Clause of the U.S. Constitution by offering the tax incentives. A federal district court disagreed, ruling for DaimlerChrysler, but on appeal a panel of the Sixth Circuit Court of Appeals reversed. The panel found that the tax incentives coerced businesses to expand in Ohio at the expense of other states, and were therefore unconstitutional manipulations of interstate commerce.

Question

Did Ohio violate the Commerce Clause of the U.S. Constitution by giving businesses tax incentives to expand their manufacturing operations inside Ohio?

Conclusion

Decision: 9 votes for DaimlerChrysler Corp., 0 vote(s) against
Legal provision: Article 3, Section 2, Paragraph 1: Case or Controversy Requirement

The Supreme Court did not reach the central question presented, finding instead that Cuno and the other plaintiffs did not have standing to bring the suit. Chief Justice John Roberts, for the unanimous Court, wrote that simply alleging standing based on their status as taxpayers in Ohio and Michigan did not give them a sufficiently strong interest in the case. The citizens from Ohio could not definitively show that the tax incentives had decreased the amount of money available to the state treasury (and thus increased their tax burden or decreased the services available to them) because the point of the incentive was to increase long-term tax revenue. The citizens from Michigan, meanwhile, could not show that any tax revenue increase in Michigan that could have resulted from DaimlerChrysler expanding there instead of in Ohio would have actually benefited them directly, because it might have been used for programs that they did not benefit from. Without any clear injury, they had no standing to sue.

Valley Forge CC v. Americans United

Mon, 20 Jun 2011 04:06:15 +0000

Location

Former land of Valley Forge General Hospital Phoenixville, PA 19460

United States

40° 7' 49.3752" N, 75° 30' 53.6868" W

See map: Google Maps

Case Basics

Docket No.

80-327

Petitioner

Valley Forge CC

Petitioner Type

Petitioner

Respondent

Americans United

Respondent Type

Respondent

Heard By

Burger Court (1981-1986)

Decided By

Burger Court (1981-1986)

Opinion

454 U.S. 464 (1982)

Argued

Wednesday, November 4, 1981

Decided

Tuesday, January 12, 1982

Advocates

Lee Boothby (Argued the cause for the respondents)

C. Clark Hodgson, Jr. (Argued the cause for the petitioner)

Rex E. Lee (Argued the cause for the federal parties as respondents in support of the petitioner)

Facts of the Case

The Secretary of Defense closed the Valley Forge General Hospital in an effort to reduce the number of military installations in the country. In accordance with a congressional statute regulating the dispersal of surplus government property, part of the hospital's land was given, free-of-charge, to the Valley Forge Christian College.

Question

Did the transfer of property violate the Establishment Clause of the First Amendment?

Conclusion

Decision: 5 votes for Valley Forge CC, 4 vote(s) against
Legal provision: Article 3, Section 2, Paragraph 1: Case or Controversy Requirement

The Court held that Americans United for Separation of Church and State did not have standing to sue. Justice Rehnquist argued that the group did not pass the first prong of the Court's test for taxpayer standing. Since the source of the group's complaint was not a congressional statute but the decision of a government agency to dispose of a parcel of property, and because the transaction did not involve the taxing and spending power, the group had no standing to sue.

Schlesinger v. Reservists To Stop The War

Mon, 05 Jan 2009 16:34:36 +0000

Case Basics

Docket No.

72-1188

Petitioner

Schlesinger

Petitioner Type

Petitioner

Respondent

Reservists To Stop The War

Respondent Type

Respondent

Heard By

Burger Court (1972-1975)

Decided By

Burger Court (1972-1975)

Opinion

418 U.S. 208 (1974)

Argued

Monday, January 14, 1974

Decided

Tuesday, June 25, 1974

Facts of the Case

None

Question

None

Conclusion

Decision: 6 votes for Schlesinger, 3 vote(s) against
Legal provision:

None

United States v. Richardson

Mon, 20 Jun 2011 04:06:07 +0000

Location

Central Intelligence Agency Headquarters

CIA Headquarters McLean VA 22101

McLean, VA 22101

United States

38° 57' 10.3968" N, 77° 9' 8.9316" W

See map: Google Maps

Case Basics

Docket No.

72-885

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Richardson

Respondent Type

Respondent

Heard By

Burger Court (1972-1975)

Decided By

Burger Court (1972-1975)

Opinion

418 U.S. 166 (1974)

Argued

Wednesday, October 10, 1973

Decided

Tuesday, June 25, 1974

Advocates

Robert H. Bork (Argued the cause for the United States et al.)

Osmond K. Fraenkel (Argued the cause for the respondent)

Facts of the Case

Richardson, a taxpayer interested in activities of the Central Intelligence Agency, sued the government to provide records detailing the CIA's expenditures.

Question

Does a federal taxpayer have standing to force the government to disclose expenditures of the CIA?

Conclusion

Decision: 5 votes for United States, 4 vote(s) against
Legal provision:

The Court held that Richardson did not have standing to sue. Using the two- pronged standing test of Flast v. Cohen (1968), Chief Justice Burger found that there was no "logical nexus between the status asserted [by Richardson as a taxpayer] and the claim sought to be adjudicated." It was clear to Burger that Richardson was not "a proper and appropriate party to invoke federal judicial power" on this issue.

Flast v. Cohen

Mon, 20 Jun 2011 04:06:02 +0000

Location

Congress

Constitution and Delaware Street Washington D.C. 20002

Washington 20002

United States

38° 53' 31.1496" N, 77° 0' 29.1744" W

See map: Google Maps

Case Basics

Docket No.

416

Appellee

Cohen

Petitioner Type

Appellee

Appellant

Flast

Respondent Type

Appellant

Heard By

Warren Court (1967-1969)

Decided By

Warren Court (1967-1969)

Opinion

392 U.S. 83 (1968)

Argued

Tuesday, March 12, 1968

Decided

Monday, June 10, 1968

Advocates

Sam J. Ervin, Jr. (Argued the cause for Americans for Public Schools et al., as amici curiae, urging reversal)

Leo Pfeffer (Argued the cause for the appellants)

Erwin N. Griswold (Argued the cause for the appellees)

Facts of the Case

Florence Flast and a group of taxpayers challenged federal legislation that financed the purchase of secular textbooks for use in religious schools. Flast argued that such use of tax money violated the Establishment Clause of the First Amendment. A district court held that the federal courts should defer when confronted with taxpayer suits directed against federal spending programs.

Question

Did Flast, as a taxpayer, have standing to sue the government's spending program?

Conclusion

Decision: 8 votes for Flast, 1 vote(s) against
Legal provision: Article 3, Section 2, Paragraph 1: Case or Controversy Requirement

In an 8-to-1 decision, the Court rejected the government's argument that the constitutional scheme of separation of powers barred taxpayer suits against federal taxing and spending programs. In order to prove a "requisite personal stake" in such cases, taxpayers had to 1) establish a logical link between their status as taxpayers and the type of legislative enactment attacked, and 2) show the challenged enactment exceeded specific constitutional limitations imposed upon the exercise of Congressional taxing and spending power. The Court held that Flast had met both parts of the test.