Franchise Tax Board of California v. Hyatt (2016)

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Franchise Tax Board of California v. Hyatt
Seal of the United States Supreme Court.svg
Argued December 7, 2015
Decided April 19, 2016
Full case nameFranchise Tax Board of California, Petitioner v. Gilbert P. Hyatt
Docket no. 14-1175
Citations578 U.S. ___ ( more )
136 S. Ct. 1277; 194 L. Ed. 2d 431
Holding
The Nevada rule not extending the same immunities to agencies of other states as it does to its own is a "policy of hostility" and unconstitutional under the Full Faith and Credit Clause.
Court membership
Chief Justice
John Roberts
Associate Justices
Anthony Kennedy  · Clarence Thomas
Ruth Bader Ginsburg  · Stephen Breyer
Samuel Alito  · Sonia Sotomayor
Elena Kagan
Case opinions
MajorityBreyer, joined by Kennedy, Ginsburg, Sotomayor, Kagan
ConcurrenceAlito (in judgment)
DissentRoberts, joined by Thomas

Franchise Tax Board of California v. Hyatt (short: Hyatt II), 578 U.S. ___ (2016), was a United States Supreme Court case in which the Court held that the Nevada rule that does not extend the same immunities to agencies of other states as it does to its own is effectively a "policy of hostility", which is unconstitutional under the Full Faith and Credit Clause. The Court split equally on the question whether Nevada v. Hall should be overruled, effectively upholding it. [1] [2] [3] [4]

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Full Faith and Credit Clause Clause of the United States constitution

Article IV, Section 1 of the United States Constitution, the Full Faith and Credit Clause, addresses the duties that states within the United States have to respect the "public acts, records, and judicial proceedings of every other state." According to the Supreme Court, there is a difference between the credit owed to laws as compared to the credit owed to judgments. Judgments are generally entitled to greater respect than laws, in other states. At present, it is widely agreed that this Clause of the Constitution has a minimal impact on a court's choice of law decision provided that no state’s sovereignty is infringed, although this Clause of the Constitution was once interpreted to have greater impact.

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Friedrichs v. California Teachers Association, 578 U.S. ___ (2016), is a United States labor law case that came before the Supreme Court of the United States. At issue in the case was whether Abood v. Detroit Board of Education (1977) should be overruled, with public-sector "agency shop" arrangements invalidated under the First Amendment, and whether it violates the First Amendment to require that public employees affirmatively object to subsidizing nonchargeable speech by public-sector unions, rather than requiring employees to consent affirmatively to subsidizing such speech. Specifically, the case concerned public sector collective bargaining by the California Teachers Association, an affiliate of the National Education Association.

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Spokeo, Inc. v. Robins, 578 U.S. 330 (2016), was a United States Supreme Court case in which the Court vacated and remanded a ruling by United States Court of Appeals for the Ninth Circuit on the basis that the Ninth Circuit had not properly determined whether the plaintiff has suffered an "injury-in-fact" when analyzing whether he had standing to bring his case in federal court. The Court did not discuss whether "the Ninth Circuit’s ultimate conclusion — that Robins adequately alleged an injury in fact — was correct."

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Knick v. Township of Scott, Pennsylvania, No. 17-647, 588 U.S. ___ (2019), was a case before the Supreme Court of the United States dealing with compensation for private property owners when the use of that property is taken from them by state or local governments, under the Due Process Clause of the Fifth Amendment to the United States Constitution. The immediate question asks if private land owners must exhaust all state-offered venues for mediation before seeking action in the federal courts. The case specifically addresses the Court's prior decision from the 1985 case Williamson County Regional Planning Commission v. Hamilton Bank of Johnson City, which had previously established that all state court venues must be exhausted first, but which has since resulted in several split decisions among circuit courts. The Supreme Court ruled in June 2019 to overturn part of Williamson County that required state venue action be taken first, allowing taking-compensation cases to be brought directly to federal court.

Franchise Tax Board of California v. Hyatt, 587 U.S. ___ (2019), was a United States Supreme Court case that determined that unless they consent, states have sovereign immunity from private suits filed against them in the courts of another state. The 5–4 decision overturned precedent set in a 1979 Supreme Court case, Nevada v. Hall. This was the third time that the litigants had presented their case to the Court, as the Court had already ruled on the issue in 2003 and 2016.

Nevada v. Hall, 440 U.S. 410 (1979), was a United States Supreme Court case that ruled that U.S. states lack sovereign immunity from private lawsuits filed against them in the courts of another state. The majority opinion held that "nothing in the Constitution authorizes or obligates" states to grant sister states immunity in court. States may grant sister states immunity if they choose. This decision was overturned by the 2019 case Franchise Tax Board of California v. Hyatt.

Franchise Tax Board of California v. Hyatt, 538 U.S. 488 (2003), was a United States Supreme Court case in which the Court unanimously held that the Full Faith and Credit Clause does not require Nevada state courts to give full faith and credit to California statutes that immunize its tax agencies from suit.

There have been three U.S. Supreme Court cases titled Franchise Tax Board of California v. Hyatt:

References

  1. "Franchise Tax Board of California v. Hyatt". Oyez. Retrieved 2020-05-15.
  2. "Franchise Tax Bd. of Cal. v. Hyatt, 578 U.S. ___ (2016)". Justia Law. Retrieved 2020-05-15.
  3. Gutoff, Jonathan M. (2017). "Franchise Tax Board of California v. Hyatt: A Split Court, Full Faith and Credit, and Federal Common Law". Roger Williams University Law Review. 22: 248.
  4. Hananel, Sam (2016-04-20). "Tie leaves states facing lawsuits in other states". Reno Gazette-Journal.