National Private Truck Council, Inc. v. Oklahoma Tax Comm'n, 515 U.S. 582 (1995)

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582

OCTOBER TERM, 1994

Syllabus

NATIONAL PRIVATE TRUCK COUNCIL, INC., et al. v. OKLAHOMA TAX COMMISSION et al.

certiorari to the supreme court of oklahoma

No. 94-688. Argued April 18, 1995—Decided June 19, 1995

In the Oklahoma state courts, petitioners successfully challenged certain state taxes as violating the "dormant" Commerce Clause. The Oklahoma Supreme Court ordered respondents to award refunds pursuant to state law, but declined to award declaratory or injunctive relief under 42 U. S. C. 1983 or attorney's fees under 1988. The court reasoned that because adequate remedies existed under state law, the Tax Injunction Act would have precluded petitioners from seeking an injunction in federal court; although that Act does not apply to state courts, the Oklahoma Supreme Court invoked the principle of "intrastate uniformity" to conclude that petitioners were not entitled to injunctive or declaratory relief under 1983.

Held: 1. Section 1983 provides no basis for courts to issue injunctive or declaratory relief in state tax cases when there is an adequate remedy at law. This Court has long held that courts should adopt a hands-off approach with respect to state tax administration. Dows v. Chicago, 11 Wall. 108, 110. In passing 1983, Congress did not limit this strong background principle of noninterference with state taxation. Construing 1983 with this principle in mind, the Court concludes that 1983 does not call for courts—whether federal or state—to disrupt state tax administration by issuing injunctive or declaratory relief when state law furnishes an adequate legal remedy. Pp. 588-592. 2. Since no relief could be awarded under 1983, no attorney's fees can be awarded under 1988. P. 592. 879 P. 2d 137, affirmed.

Thomas, J., delivered the opinion for a unanimous Court. Kennedy, J., filed a concurring opinion, post, p. 592.

Richard A. Allen argued the cause for petitioners. With him on the briefs was Richard P. Schweitzer.

Stanley P. Johnston argued the cause for respondents. With him on the brief was Robert B. Struble.*

*Briefs of amici curiae urging reversal were filed for the Direct Marketing Association, Inc., by George S. Isaacson, Martin I. Eisenstein, and

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