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 sought relief in State Court in Michigan, claiming the seizure and sale of the land were invalid because no one personally handed over the notice.
  • Darue moved the case to Federal Court.  They argued that the Federal District Court had proper jurisdiction.
    • There are three ways to get a case heard before a Federal Court: a conflict between parties in two different States, a question regarding the United States Constitution, or a question regarding the Federal laws of the United States.
    • Darue argues that the case turns on the wording of the IRS code, making it a federal question.
    • Grable argued that a violation of a Federal law doesn't necessarily make it a substantial federal interest.  This case arose in Michigan between two private parties.
  • 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 disagreed.
  • Grable appealed to the Federal Appellate Court, arguing that the Trial Court  made two errors:
    • First, although based on Federal tax law, Grable said its case did not present a federal question and should be heard in a State Court.
    • Second, Grable renewed its claim that the IRS did not follow the rules in seizing the property, voiding the sale to Darue.
  • Federal Appellate Court affirmed.  Grable appealed to the Supreme Court.
  • US Supreme Court unanimously affirmed, siding 9-0 against Grable and holding that the national interest in providing a federal forum for such tax litigation is sufficiently substantial to support the exercise of federal question jurisdiction.