Justia Government & Administrative Law Opinion Summaries

Marathon Petroleum Company LP (Marathon) was audited by the Cook County Department of Revenue (Department) for gasoline and diesel transactions between January 2006 and July 2014. The Department determined that Marathon failed to collect and remit taxes on certain transactions, specifically "book transfers," and assessed taxes, interest, and penalties. Marathon argued that these transactions were financial settlements of forward contracts, not taxable sales, and sought administrative review.An administrative law judge (ALJ) upheld the Department's assessments, finding that Marathon did not provide sufficient documentary evidence to prove that the book transfers did not involve a change of ownership or movement of fuel. Marathon then sought judicial review, and the circuit court reversed the ALJ's decision, finding that the Department's assessments were unreasonable and that Marathon had provided sufficient evidence to rebut the Department's prima facie case.The appellate court reversed the circuit court's decision, affirming in part the ALJ's decision and remanding for a recalculation of the amount due. The appellate court held that the Department's auditing method was reasonable and that Marathon did not meet its burden of rebutting the Department's prima facie case. The appellate court also found that the transfer of an intangible ownership interest was enough to make the book out transactions taxable.The Supreme Court of Illinois reviewed the case and found that the ALJ misunderstood some of the evidence presented by Marathon. The court held that Marathon provided sufficient documentary evidence to rebut the Department's prima facie case and that the ALJ's conclusion was clearly erroneous. The court reversed the appellate court's judgment, affirmed in part and reversed in part the circuit court's judgment, and remanded the case to the Cook County Department of Administrative Hearings for further proceedings to determine if the Department can prove its case of taxability under the Fuel Tax Ordinance. View "Marathon Petroleum Co. LP v. Cook County Department of Revenue" on Justia Law

Appellant A. Thomas Jones challenged the City of Atlanta's imposition of charges through two ordinances, arguing that these charges, levied on the Department of Watershed Management (DWM) customers, are unlawful taxes. The ordinances in question impose a franchise fee on DWM's gross revenue and a payment in lieu of taxes (PILOT) on DWM's real property, with the collected sums deposited into the City's General Fund. Jones contended that these charges exceed the costs they purportedly cover and are instead used to generate general revenue, violating various constitutional and statutory provisions.The trial court initially dismissed Jones's suit on procedural grounds, but the Court of Appeals reversed this decision in part. Upon remand, the City moved for judgment on the pleadings, and Jones filed motions for partial summary judgment. The trial court granted the City's motion and denied Jones's motions, leading to this appeal. Jones argued that the trial court erred in its application of the standard of review and in its conclusions regarding the nature of the charges.The Supreme Court of Georgia reviewed the case and found that the trial court erred in granting the City's motion for judgment on the pleadings. The Supreme Court held that the trial court failed to treat Jones's allegations as true, particularly his claims that he paid the disputed charges, that the revenue generated from these charges grossly exceeded the associated costs, and that these costs were covered by other transfers from DWM to the City's General Fund. Consequently, the Supreme Court vacated the trial court's judgment on the pleadings and remanded the case for further proceedings.However, the Supreme Court affirmed the trial court's denial of Jones's motions for partial summary judgment. The Court concluded that Jones failed to demonstrate the absence of genuine disputes of material fact regarding whether the charges were taxes or fees and whether the revenue generated exceeded the associated costs. The case was remanded for reconsideration of Jones's claims under the proper standard of review. View "Jones v. City of Atlanta" on Justia Law

Jim Walsh, a member of the Washington State House of Representatives, along with other appellants, submitted six initiatives to the legislature. Three of these initiatives were enacted, while the remaining three—repealing the Washington Climate Commitment Act, repealing the state’s capital gains tax, and making participation in the state’s long-term care insurance program optional—were set to appear on the November 2024 ballot. The appellants sought to prevent public investment impact disclosures from appearing on the ballot, arguing that these disclosures were not warranted.The Thurston County Superior Court denied the appellants' request for writs of mandamus and prohibition, dismissing their complaint. The court found that the capital gains tax was not impliedly repealed by another initiative and that the other two initiatives did indeed modify a "tax or fee," thus requiring public investment impact disclosures. The appellants then appealed directly to the Supreme Court of the State of Washington.The Supreme Court of the State of Washington affirmed the lower court's decision. The court held that the writs of prohibition and mandamus were not appropriate in this case. The attorney general and the secretary of state were acting within their jurisdiction and statutory obligations. The court also noted that the appellants had not demonstrated the absence of a plain, speedy, and adequate remedy in the ordinary course of legal proceedings. Therefore, the trial court's denial of relief and dismissal of the case were upheld. View "Walsh v. Hobbs" on Justia Law

The State of Wyoming owns a 3.37-acre parcel in Uinta County, leased to Pilot Corporation for operating a truck stop. The property, held for the benefit of the Wyoming State Hospital, generates revenue for the hospital through the lease. In 2022, the Uinta County Assessor assessed the property for taxation, which the State contested, claiming the property was used primarily for a governmental purpose and thus exempt from taxation.The County Board of Equalization initially ruled in favor of the State, stating the property was used for a governmental purpose because the Board of Land Commissioners had a fiduciary duty to generate revenue for the hospital. However, the State Board of Equalization reversed this decision, holding that the Department of Revenue’s rules, which state that governmental property used by a lessee for non-governmental purposes is not tax-exempt, were binding. The district court affirmed the State Board’s decision, agreeing that the lessee’s use of the property for a truck stop did not constitute a governmental purpose.The Wyoming Supreme Court reviewed the case and affirmed the district court’s ruling. The Court held that the property was not exempt from taxation because it was used by the lessee, Pilot Corporation, for a non-governmental purpose. The Court emphasized that the end use of the property by the lessee determines its tax status, not the purpose of the lease. Additionally, the Court found that the legislature had not provided an exemption for such properties, as required by the Wyoming Constitution. Therefore, the property was subject to taxation. View "State of Wyoming v. Uinta County Assessor" on Justia Law

Circle of Seasons Charter School (Charter School) purchased two properties from The Pennsylvania State University (PSU) in May 2017. These properties were previously tax-exempt as part of PSU's Lehigh Valley Campus. Following the sale, Lehigh County issued assessment notices changing the properties' status from non-taxable to taxable, effective January 1, 2018. The notices did not include the required mailing date. Charter School claimed it did not receive these notices and subsequently did not pay the 2017 and 2018 tax bills until refinancing the properties in June 2018.The Lehigh County Court of Common Pleas sustained the preliminary objections of Northwestern Lehigh School District (School District) and dismissed Charter School's complaint with prejudice. The trial court found that Charter School had actual notice of the tax assessments by November 2017 and could have addressed the taxes in its 2018 annual appeal to the Lehigh County Board of Assessment Appeals (the Board). The Board granted tax-exempt status effective January 1, 2019, but Charter School did not seek retroactive relief or a refund for the taxes paid for 2017 and 2018.The Commonwealth Court reversed the trial court's decision, ruling that the defective notices entitled Charter School to a nunc pro tunc hearing before the Board to determine the validity of the assessment changes and potential refunds. The court emphasized that the omission of the mailing date on the notices was a significant defect, warranting a new hearing.The Supreme Court of Pennsylvania reversed the Commonwealth Court's decision, reinstating the trial court's order. The Supreme Court held that Charter School had the burden to establish the properties' tax-exempt status and failed to do so in a timely manner. The court concluded that Charter School waived its claims by not seeking retroactive relief or a refund during the 2018 appeal and that nunc pro tunc relief was not warranted. View "Circle of Seasons Chart School v. Northwestern Lehigh School District" on Justia Law

A group of landowners challenged the Ohio Tax Commissioner’s decision to set a woodland-clearing-cost rate of $1,000 per acre for the purpose of calculating the current agricultural use valuation (CAUV) of their properties for tax years 2015 through 2020. The landowners argued that the rate was too low and not based on reliable evidence, causing their woodlands to be overvalued and resulting in higher property taxes.The Board of Tax Appeals (BTA) upheld the Tax Commissioner’s decision, finding that the Commissioner did not abuse her discretion in setting the $1,000 rate. The BTA concluded that the rate was within the Commissioner’s discretion and based on input from the agricultural advisory committee. The BTA also rejected the Tax Commissioner’s argument that some landowners lacked standing to challenge the CAUV entries for certain years.The Supreme Court of Ohio reviewed the case and found that the Tax Commissioner abused her discretion by adopting the $1,000 rate without reliable evidence or a sound reasoning process. The court noted that the decision was arbitrary and not supported by any fixed rules or standards. The court also found that the Tax Commissioner failed to comply with Ohio Administrative Code 5703-25-33, which requires obtaining information from reliable sources and ensuring that CAUV tables are accurate, reliable, and practical.The Supreme Court of Ohio reversed the BTA’s decision and remanded the case to the Tax Commissioner with instructions to adopt a woodland-clearing-cost rate that complies with the administrative code. The court emphasized that the Tax Commissioner must base the rate on reliable evidence and follow the prescribed standards. View "Adams v. Harris" on Justia Law

The case involves James Harper, who challenged an IRS "John Doe" summons issued to Coinbase, a cryptocurrency exchange, seeking records of numerous customers, including Harper. Harper argued that the IRS's actions violated his Fourth and Fifth Amendment rights and did not meet statutory requirements under the Administrative Procedure Act (APA). The IRS had issued the summons to investigate potential tax noncompliance among Coinbase users.The United States District Court for the District of New Hampshire dismissed Harper's complaint. The court found that Harper lacked a reasonable expectation of privacy in his Coinbase account information and that the records were Coinbase's property, not Harper's. The court also concluded that the IRS summons was reasonable and that Harper had received constitutionally adequate process. Additionally, the court dismissed Harper's statutory challenge, ruling it was an improper collateral attack on prior district court proceedings that had enforced the summons and found it met statutory standards.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that Harper lacked a protectable interest under the Fourth or Fifth Amendment. It held that Harper had no reasonable expectation of privacy in the information he voluntarily provided to Coinbase and that the records were Coinbase's property. The court also found that Harper's due process claim failed because he had no protected liberty interest in the confidentiality of his financial information. Finally, the court ruled that the IRS summons was not "final agency action" under the APA, thus not subject to judicial review.The First Circuit affirmed the district court's dismissal of Harper's complaint, concluding that Harper's constitutional and statutory claims were without merit. View "Harper v. Werfel" on Justia Law

Robert Turner, a property owner in Suwannee County, Florida, claimed that his homestead property was sold at an impermissibly low amount under Florida law, which deprived him of any surplus after back taxes and costs were deducted. Turner had a homestead exemption on his property, which was automatically renewed until 2015. After failing to pay property taxes, a tax certificate was issued, and a tax deed sale was conducted in 2015. Turner alleged that the sale was unlawful because it did not account for the homestead exemption, and he did not receive proper notice of the sale.Turner initially sought relief in state court, challenging the removal of his homestead exemption, but his complaint was dismissed as untimely. He then filed a federal lawsuit under 42 U.S.C. § 1983, claiming violations of his constitutional rights, including First Amendment retaliation, Fourth Amendment illegal seizure, and due process violations. The federal district court dismissed his complaint, finding that abstention was warranted under the comity doctrine, which prevents federal courts from interfering with state tax administration when state remedies are adequate.The United States Court of Appeals for the Eleventh Circuit reviewed the district court's decision. The court affirmed the dismissal, holding that the relief Turner sought would disrupt Florida's administration of its ad valorem property tax scheme. The court found that Florida provided plain, adequate, and complete state remedies, including the ability to challenge tax deed sales and homestead exemption removals in state court. The court concluded that the district court did not abuse its discretion in abstaining from exercising jurisdiction under the comity doctrine. View "Turner v. Jordan" on Justia Law

Eight rural electric cooperatives (RECs) sought judicial review after the Kansas Board of Tax Appeals (BOTA) denied their property valuation challenges for the 2019 and 2020 tax years. The RECs argued that the valuation methodology used by the Kansas Department of Revenue's Property Valuation Division (PVD) violated the requirement for "generally accepted appraisal procedures" under K.S.A. 79-5a04. The RECs elected to go to district court for a trial de novo, which allows for an evidentiary hearing where issues of law and fact are determined anew.The Shawnee County District Court agreed with the RECs, concluding that PVD's valuation methodology violated K.S.A. 79-5a04. The court found that the methodology resulted in non-uniform and unequal valuations of the RECs' properties, thus inflating their property values and taxes. The district court ordered PVD to adjust its methodology to account for the RECs' treatment of margin stabilization adjustments (MSAs) in their net operating income (NOI).On appeal, the Kansas Supreme Court reviewed whether the district court exceeded its scope of judicial review by considering issues not raised before BOTA. The Supreme Court held that a trial de novo under K.S.A. 2023 Supp. 74-2426(c)(4)(B) does not expand a district court's scope of judicial review beyond what is permitted by K.S.A. 77-617. The court determined that the RECs had only raised a constitutional issue regarding uniform and equal taxation before BOTA, not a statutory compliance issue under K.S.A. 79-5a04. Therefore, the district court exceeded its scope of review by deciding on the statutory issue.The Kansas Supreme Court reversed the district court's judgment, holding that the district court improperly expanded its scope of review by addressing the statutory compliance issue that was not litigated before BOTA. View "FreeState Electric Cooperative, Inc. v. Kansas Dept. of Revenue" on Justia Law

A former employee of Credit Suisse, John Doe, filed a qui tam action under the False Claims Act (FCA) alleging that the bank failed to disclose ongoing criminal conduct to the United States, thereby avoiding additional penalties. This followed Credit Suisse's 2014 guilty plea to conspiracy charges for aiding U.S. taxpayers in filing false tax returns, which included a $1.3 billion fine. Doe claimed that Credit Suisse continued its illegal activities post-plea, thus defrauding the government.The United States District Court for the Eastern District of Virginia granted the government's motion to dismiss the case. The government argued that Doe's allegations did not state a valid claim under the FCA and that continuing the litigation would strain resources and interfere with ongoing obligations under the plea agreement. The district court dismissed the action without holding an in-person hearing, relying instead on written submissions from both parties.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The court held that the "hearing" requirement under 31 U.S.C. § 3730(c)(2)(A) of the FCA can be satisfied through written submissions and does not necessitate a formal, in-person hearing. The court found that Doe did not present a colorable claim that his constitutional rights were violated by the dismissal. The court emphasized that the government has broad discretion to dismiss qui tam actions and that the district court properly considered the government's valid reasons for dismissal, including resource conservation and the protection of privileged information. The Fourth Circuit concluded that the district court's dismissal was appropriate and affirmed the judgment. View "United States ex rel. Doe v. Credit Suisse AG" on Justia Law