DaimlerChrysler Corp. v. Cuno Case Brief

Facts of the Case

Under a contract with a city, defendant automobile manufacturer agreed to expand its local assembly plant in exchange for the city agreeing to waive the property tax for the plant. Because the manufacturer undertook to purchase and install new manufacturing machinery and equipment, it was also entitled to a credit against the state franchise tax. Most of the plaintiffs were residents of the city, who paid taxes to both the city and the State of Ohio. They claimed that they were injured because the tax breaks for the manufacturer diminished the funds available to the city and State, imposing a disproportionate burden on them. Plaintiff local taxpayers sued alleging that tax breaks for defendant automobile manufacturer violated the. Defendant state and local officials and the automobile manufacturer sought certiorari to review the United States Court of Appeals’ invalidation of a franchise tax credit, and the taxpayers sought certiorari to review the Court of Appeals’ upholding of a property tax exemption. Certiorari was granted.

Question

“(1) Has a person who is not under the physical control of a police officer been “seized” under the Fourth Amendment when the officer is chasing that person?(2) Can a person who is pursued by a police officer avoid prosecution by discarding incriminating evidence and asserting that he did so out of fear of an unlawful search?”

CONCLUSION

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.

Case Information

Citation: 547 US 332 (2006)
Granted: Sep 27, 2005
Argued: Mar 1, 2006
Decided: May 15, 2006
Case Brief: 2006