State tax reporting rules
Direct Marketing Association v. Barbara Brohl
In brief
The Supreme Court decided the Tax Injunction Act does not block the association's suit, but left the legality of Colorado's rules undecided.
- Where it stands
- Decided
Decided 9-0 · March 3, 2015 · Opinion by Justice Thomas
- What it’s about
- The Direct Marketing Association challenged Colorado rules requiring some out-of-state retailers that do not collect the state’s use tax to notify customers and report purchases to Colorado.
- Who it affects
- The Tax Injunction Act does not bar the Direct Marketing Association's federal suit, but the ruling does not decide whether Colorado's rules are lawful.
Summary: written with AI from the case record.
What it's about
The Supreme Court ruled that the Tax Injunction Act did not block the federal suit, overturned the appeals court’s ruling, and sent the case back to that court (remanded); it did not decide whether the rules are lawful.
Colorado's rules required certain out-of-state retailers that did not collect the state's use tax to notify customers and report their purchases to the state.
Question presented
Does the Tax Injunction Act bar federal court jurisdiction over a suit brought by non-taxpayers to enjoin the enforcement of notice-and-reporting requirements of state tax law that neither impose nor require the collection of a tax?
What the Court decided
Holding
Petitioner’s suit is not barred by the TIA. 735 F. 3d 904, reversed and remanded.
- Result
- Reversed
The vote
What's next
The case returns to the Tenth Circuit for further proceedings. Whether Colorado's rules are lawful remains unresolved.
Documents
Opinions
Docket activity
New analysis added
AI analysis generated: Impact Analysis
AI analysis generated: Opinion Summary
New analysis added
AI analysis generated: Case Briefing
Show 4 moreShow fewer
AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
Case data updated: question_presented, extraction_metadata
Opinion added: Brohl
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.