Cite as: 527 U. S. 423 (1999)
Opinion of the Court
solely for purposes of this jurisdictional inquiry, that measure required the judges to pay a license fee before "engag[ing] in [their] occupation." Ordinance No. 1120, § 2. The circumstances that gave rise to the tax liability, not just the taxpayers' refusal to pay, "constitute the basis" for the tax collection lawsuits at issue. See Willingham, 395 U. S., at 409 (" It is enough that [petitioners'] acts or [their] presence at the place in performance of [their] official duty constitute the basis . . . of the state prosecution." (internal quotation marks omitted)). Here, those circumstances encompass holding court in the county and receiving income for that activity. In this light, we are satisfied that the judges have shown the essential nexus between their activity "under color of office" and the county's demand, in the collection suits, for payment of the local tax.
III
The Tax Injunction Act provides:
"The district courts shall not enjoin, suspend or restrain the assessment, levy or collection of any tax under State law where a plain, speedy and efficient remedy may be had in the courts of such State." 28 U. S. C. § 1341.
This statutory text "is to be enforced according to its terms" and should be interpreted to advance "its purpose" of "confin[ing] federal-court intervention in state government." Arkansas v. Farm Credit Servs. of Central Ark., 520 U. S. 821, 826-827 (1997). By its terms, the Act bars anticipatory relief, suits to stop ("enjoin, suspend or restrain") the collection of taxes. Recognizing that there is "little practical difference" between an injunction and anticipatory relief in the form of a declaratory judgment, the Court has held that declaratory relief falls within the Act's compass. California v. Grace Brethren Church, 457 U. S. 393, 408 (1982). But a suit to collect a tax is surely not brought to restrain state
433
Page: Index Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 NextLast modified: October 4, 2007