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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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. It was followed by Hyatt II in 2016 and Hyatt III in 2019, ultimately overturning precedent set by the 1979 Supreme Court case, Nevada v. Hall.

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 May 15, 2020.
  2. "Franchise Tax Bd. of Cal. v. Hyatt, 578 U.S. ___ (2016)". Justia Law. Retrieved May 15, 2020.
  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 (April 20, 2016). "Tie leaves states facing lawsuits in other states". Reno Gazette-Journal.