National Private Truck Council, Inc. v. Oklahoma Tax Commission

PETITIONER: National Private Truck Council, Inc., et al.
RESPONDENT: Oklahoma Tax Commission et al.
LOCATION: U.S. Department of Transportation

DOCKET NO.: 94-688
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: Supreme Court of Oklahoma

CITATION: 515 US 582 (1995)
ARGUED: Apr 18, 1995
DECIDED: Jun 19, 1995

ADVOCATES:
Richard A. Allen - on behalf of the Petitioners
Stanley P. Johnston - on behalf of the Respondent

Facts of the case

Question

Media for National Private Truck Council, Inc. v. Oklahoma Tax Commission

Audio Transcription for Oral Argument - April 18, 1995 in National Private Truck Council, Inc. v. Oklahoma Tax Commission

Audio Transcription for Opinion Announcement - June 19, 1995 in National Private Truck Council, Inc. v. Oklahoma Tax Commission

William H. Rehnquist:

The opinion of the court in number 94-688, National Private Truck Council v. the Oklahoma Tax Commission will be announced by Justice Thomas.

Clarence Thomas:

This case comes to us on a writ of certiorari to the Oklahoma Supreme Court.

In order to retaliate against states that impose what it considers discriminatory taxes on trucks registered in Oklahoma.

The state of Oklahoma similarly imposed taxes on trucks that conducted business in that state but were registered in the offending states.

Pursuant to state law and 42 U.S.C. 1983 petitioners filed a class action in the state of Oklahoma courts challenging the taxes as unconstitutional.

Petitioners sought refunds declaratory and injunctive relief as well as attorney’s fees under section 1988.

After a series of decisions in the Oklahoma courts and the remand from this court, the Oklahoma Supreme Court held that the taxes were unconstitutional and ordered Oklahoma to award refunds pursuant to state law relying upon the principle of interstate uniformity.

The court did not grant injunctive or declaratory relief under 1983.

The court reasoned that petitioner should not secure relief in state court that could not be awarded in Federal Court because it granted no relief under section 1983 the court did not award attorney’s fees under section 1988.

In an opinion filed with the clerk today we affirm the long standing federal reluctance to interfere with state taxation leads us to conclude that in state tax cases congress did not authorize courts to issue declaratory or injunctive relief when an adequate remedy exists at law.

Our cases have made clear that injunctive and declaratory relief have the potential to disrupt the administration of state taxes.

Before the passage of section 1983 this potential for disruption led to the establishment of a principle of noninterference with state taxation when there is an adequate remedy at law.

As our subsequent cases indicate section 1983 did not disturb this principle.

Construing § 1983 in light of this principle we conclude that congress has not authorized courts to award equitable or declaratory relief when an adequate remedy at law exist.

Justice Kennedy has filed a concurring opinion.