Grable & Sons Metal Products Inc. v. Darue Engineering and Manufacturing
125 S. Ct. 2363 (2005)
Beginning in 1988, Grable
& Sons Metal Products, Inc. did not pay corporate income taxes six
years in a row.
Sticking it to the man!
Finally, in 1994, the IRS
seized Grable's property in Michigan to pay the debt. But instead of
hand-delivering the notice of seizure to Grable, as IRS regulations
require, they sent it certified mail.
Grable received the notice
and did not argue when the IRS took the property, or when the land was
later sold to Darue.
Six years after that, Grable
sued Darue in a Michigan State Court.
Grable claimed that the IRS
seizure and sale of the land were invalid because no one personally
handed over the notice.
Darue moved the case to
Federal Court.
There are three ways to get
a case heard before a Federal Court:
A conflict between parties
in two different States,
aka diversity
jurisdiction.
A question regarding the
United States Constitution, or
aka a federal question.
A question regarding the
Federal laws of the United States.
In this case, Darue argued
that the case turned on the wording of the IRS code, making it a federal
question. Therefore the Federal
Court had proper jurisdiction.
Grable asked to be moved back
to the State Court, claiming the Federal Court didn't have the authority
to hear the case. Federal Trial Court denied the motion. Grable appealed.
Grable argued that a
violation of a Federal law doesn't necessarily make it a substantial
federal interest. Although the case originated in Federal tax law,
Grable's lawsuit was between two private Michigan residents about some
property in Michigan. It had nothing to do with the Federal government,
so it wasn't a federal question
and there was no diversity jurisdiction so it shouldn't be heard in a Federal court.
The Federal Appellate Court
affirmed. Grable appealed.
Federal Appellate Court
affirmed. Grable appealed.
US Supreme Court affirmed.
The US Supreme Court found
that the national interest in providing a federal forum for such tax
litigation is sufficiently substantial to support the exercise of federal
question jurisdiction.