Cite as: 503 U. S. 594 (1992)
Opinion of the Court
tirees, two class actions were filed in Kansas District Court challenging the state income tax imposed on military retirement benefits. Together the classes comprised some 14,000 military retirees, who received federal Armed Forces retirement benefits and were subject to the Kansas income tax for one or more of the tax years from 1984 through 1989. The classes also included spouses of the retirees, where applicable. Plaintiff taxpayers sought a declaratory judgment that the Kansas income tax discriminates against them in favor of state and local government retirees, in violation of § 111 and the constitutional principles of intergovernmental tax immunity applied in Davis. They also requested a permanent injunction to prohibit assessment of the tax against military retirees, as well as refunds of any taxes paid by class members for the tax years 1984 through 1989.2 The District Court granted summary judgment for the defendants, and the Supreme Court of Kansas affirmed, 249 Kan. 186, 815 P. 2d 46 (1991). We granted certiorari because the holding below is arguably inconsistent with our decision in Davis and conflicts with decisions of other state courts of last resort. 502 U. S. 977 (1991).3
Our approach to deciding this case is controlled by Davis, which invalidated a Michigan law that imposed taxes on federal civil service retirees' benefits but not on benefits received by state and local government retirees. In reaching
2 The taxpayers also relied on the Supremacy Clause of the United States Constitution, the Privileges and Immunities Clause of the Fourteenth Amendment, and Article 11, § 2, of the Kansas Constitution. The taxpayers further alleged that the State deprived them of their civil rights as secured by the United States Constitution and laws in violation of the Fourteenth Amendment and of 42 U. S. C. § 1983. See 249 Kan., at 188, 815 P. 2d, at 48.
3 See, e. g., Kuhn v. State, 817 P. 2d 101 (Colo. 1991) (en banc); Pledger v. Bosnick, 306 Ark. 45, 811 S. W. 2d 286 (1991); and Hackman v. Director of Revenue, 771 S. W. 2d 77 (Mo. 1989) (en banc), cert. denied, 493 U. S. 1019 (1990).
597
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