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- NOTE: Where it is feasible, a syllabus (headnote) will be released, as is
- being done in connection with this case, at the time the opinion is issued.
- The syllabus constitutes no part of the opinion of the Court but has been
- prepared by the Reporter of Decisions for the convenience of the reader.
- See United States v. Detroit Lumber Co., 200 U. S. 321, 337.
-
- SUPREME COURT OF THE UNITED STATES
-
- Syllabus
-
- NATIONAL PRIVATE TRUCK COUNCIL, INC., et
- al. v. OKLAHOMA TAX COMMISSION et al.
- certiorari to the supreme court of oklahoma
- No. 94-688. Argued April 18, 1995-Decided June 19, 1995
-
- In the Oklahoma state courts, petitioners successfully challenged
- certain state taxes as violating the dormant commerce clause. The
- Oklahoma Supreme Court ordered respondents to award refunds
- pursuant to state law, but declined to award declaratory or injunc-
- tive relief under 42 U. S. C. 1983 or attorney's fees under 1988.
- The court reasoned that because adequate remedies existed under
- state law, the Tax Injunction Act would have precluded petitioners
- from seeking an injunction in federal court; although that Act does
- not apply to state courts, the Oklahoma Supreme Court invoked the
- principle of ``intrastate uniformity'' to conclude that petitioners were
- not entitled to injunctive or declaratory relief under 1983.
- Held:
- 1. Section 1983 provides no basis for courts to issue injunctive or
- declaratory relief in state tax cases when there is an adequate
- remedy at law. This Court has long held that courts should adopt
- a hands-off approach with respect to state tax administration. Dows
- v. City of Chicago, 11 Wall. 108, 110. In passing 1983, Congress
- did not limit this strong background principle of noninterference
- with state taxation. Construing 1983 with this principle of nonin-
- terference in mind, the Court concludes that 1983 does not call for
- courts-whether federal or state-to disrupt state tax administration
- by issuing injunctive or declaratory relief when state law furnishes
- an adequate legal remedy. Pp. 6-10.
- 2. Since no relief could be awarded under 1983, no attorney's
- fees can be awarded under 1988. P. 10.
- 879 P. 2d 137, affirmed.
- Thomas, J., delivered the opinion for a unanimous Court. Kennedy,
- J., filed a concurring opinion.
-