Nat'l Private Truck Council v. Okla. Tax Comm'n

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In Nat'l Private Truck Council v. Okla. Tax Comm'n, 515 U.S. 582 (1995), the U.S. Supreme Court held that the Tax Injunction Act has the effect of prohibiting state courts from enjoining the collection of state taxes pursuant to the federal statute of Section 1983. "When a litigant seeks declaratory or injunctive relief against a state tax pursuant to § 1983, ... state courts, like their federal counterparts, must refrain from granting federal relief under § 1983 when there is an adequate legal remedy."

Justice Clarence Thomas wrote the opinion for a unanimous Court.

The facts of this case arose from a successful demand for a refund for taxes by Oklahoma state courts, by arguing that the state taxes violate the "dormant" Commerce Clause. Although the Oklahoma Supreme Court ordered respondents to award refunds pursuant to state law, it also held that petitioners were not entitled to declaratory or injunctive relief under Rev. Stat. § 1979, 42 U.S.C. § 1983, and, accordingly, that they could not obtain attorney's fees under 42 U.S.C. § 1988(b) (1988 ed., Supp. V). Petitioners argued that this holding violates the Supremacy Clause, U.S. Const., Art. VI, cl. 2, but the Court affirmed the denial of attorneys' fees by the Oklahoma Supreme Court.