United States v. Williams

PETITIONER: United States
RESPONDENT: Williams
LOCATION: Georgia General Assembly

DOCKET NO.: 94-395
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Ninth Circuit

CITATION: 514 US 527 (1995)
ARGUED: Feb 22, 1995
DECIDED: Apr 25, 1995

ADVOCATES:
Kent L. Jones - on behalf of the Petitioner
Philip Garrett Panitz - on behalf of the Respondent

Facts of the case

Question

Media for United States v. Williams

Audio Transcription for Oral Argument - February 22, 1995 in United States v. Williams

Audio Transcription for Opinion Announcement - April 25, 1995 in United States v. Williams

William H. Rehnquist:

The opinion of the court in number 94-395, United States against Williams will be announced by Justice Ginsburg.

Ruth Bader Ginsburg:

This is a case about internal-revenue service tax collection.

Lori Williams, a Californian, paid under protest federal taxes she did not owe.

The internal-revenue service had assessed these taxes against Jerrold Rabin, once but no longer Williams?s husband.

Williams paid the taxes to clear a federal tax lien on the home Rabin and Williams once co-owned a home transferred entirely to Williams as part of a property division proprietary to divorce.

Williams paid under protest so that she could proceed with the sale of her house, pursuant to a contract scheduled imminently to close.

She then sought a refund, asserting that the lien was invalid, when the internal-revenue service denied her refund claim, she brought suit in the Federal District Court in California.

In response to Williams?s suit, the government said, it did not matter whether the government had a right to her money.

Her plea could not be heard in court, the government insisted, because refund suits could be brought only by the person against whom the tax had been assessed here, Williams?s former husband.

The Trial Court accepted this argument but the United States Court of Appeals for the Ninth Circuit reversed.

We granted certiorari to resolve a defensive opinion among Federal Courts of Appeals on this question.

May a person not herself assessed, a tax who nevertheless pays it under protest, in order to remove a tax lien from her property to the government for a refund.

We read the key statute on refund actions, 28 U.S.C. Section 1346(a)(1) to allow Williams suit.

That statute speaks of suits to recover any internal-revenue tax alleged to have been erroneously or illegally assessed or collected.

That language we hold covers people who pay taxes in the manner Lori Williams did.

The government relies on a chain of other statutory provisions to impose a limitation on tax refund suits that will leave Williams without a way to claim back her payment.

We do not think congress ordered the confinement of recent fund suits urged by the government.

Accordingly, we affirm the judgment of the Court of Appeals which allowed Lori Williams to maintain her refund suits.

Justice Scalia has filed a concurring opinion.

The Chief Justice has filed a dissenting opinion in which Justice Kennedy and Justice Thomas joined.