National Private Truck Council, Inc. v. Oklahoma Tax Comm'n, 515 U.S. 582, 7 (1995)

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588

NATIONAL PRIVATE TRUCK COUNCIL, INC. v. OKLAHOMA TAX COMM'N

Opinion of the Court

does not necessarily mean that, having found a violation of federal law, state courts must award declaratory and injunctive relief under § 1983 in tax cases. Though federal courts are obliged to hear § 1983 claims, it is clear that they may not award damages or declaratory or injunctive relief in state tax cases when an adequate state remedy exists. See Fair Assessment, supra, at 116; Great Lakes Dredge & Dock Co. v. Huffman, supra, at 293; Matthews v. Rodgers, 284 U. S. 521, 525 (1932); 28 U. S. C. § 1341.

As we explain more fully below, the background presumption that federal law generally will not interfere with administration of state taxes leads us to conclude that Congress did not authorize injunctive or declaratory relief under § 1983 in state tax cases when there is an adequate remedy at law.5

III

Petitioners correctly point out that the Tax Injunction Act does not prohibit state courts from entertaining § 1983 suits that seek to enjoin the collection of state taxes. Nor can a desire for "intrastate uniformity" permit state courts to refuse to award relief merely because a federal court could not grant such relief. As petitioners note, it was not until 1875 that Congress provided any kind of general federal-question jurisdiction to the lower federal courts. See Palmore v. United States, 411 U. S. 389, 401 (1973). "Until that time, the state courts provided the only forum for vindicating many important federal claims." Ibid. Because of the Supremacy Clause, state courts could not have refused to hear cases arising under federal law merely to ensure "uniform-§ 1983"). Cf. Arkansas Writers' Project, Inc. v. Ragland, 481 U. S. 221, 234, n. 7 (1987) (observing that whether state courts must assume jurisdiction over § 1983 claims involving state taxes "is not entirely clear").

5 Will v. Michigan Dept. of State Police, 491 U. S. 58, 68-69 (1989), already established that petitioners' claim for refunds against the State could not proceed under § 1983.

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