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No. 17-1299October Term 2018Decided May 13, 2019

Docket 17-1299October Term 2018 (2018–2019)

Franchise Tax Bd. of Cal. v. Hyatt

States generally cannot be hauled into another state's courts by private plaintiffs unless they consent.

Case status

Current stage
Decided
Latest event
Decision released May 13, 2019
Case Accepted
Arguments
Decision ReleasedMay 13, 2019
What it's about

This case asked whether Gilbert Hyatt could keep suing California’s Franchise Tax Board in Nevada state court for alleged misconduct during a tax audit. The Supreme Court used the case to decide whether states have sovereign immunity from private suits in other states’ courts and ultimately overruled Nevada v. Hall.

Question presented

Whether Nevada v. Hall , 440 U.S. 410 (1979), which permits a sovereign State to be haled into another State's courts without its consent, should be overruled.

Case path

Supreme Court of Nevada / Decision released May 13, 2019

Area

Decided Supreme Court case

Briefing

What it's about

The Court said California's Franchise Tax Board could not be sued in Nevada state court without California's consent. In doing so, it overruled Nevada v. Hall, which had allowed one state to be sued in another state's courts.

Vote

The Court decided that a state cannot be sued in another state's courts without its consent and overruled Nevada v. Hall. The prompt does not provide the vote count or opinion lineup.

Impact

The decision gives states stronger sovereign immunity (protection from being sued without consent) in other states' courts. For example, a person usually cannot sue another state's tax agency in their home state's courts unless that state agrees.

What's next

The Supreme Court has finished this case. The practical result is that Hyatt could not continue this suit against California's tax board in Nevada state court under the rule the Court announced.

What was the main fight in Franchise Tax Bd. of Cal. v. Hyatt?

The case asked whether Gilbert Hyatt could keep suing California's tax agency in Nevada state court. The Court used that dispute to revisit Nevada v. Hall.

Who is most affected by this decision in real life?

People trying to sue a different state's agency or officials in their own state's courts are most affected. State governments also gain stronger protection from those suits.

What happened next after the Supreme Court's decision?

The Court finished its work on this docket. The case could no longer go forward in Nevada state court on the theory that California could be sued there without consent.

Decision

Decision record

What the Court decided

States generally cannot be hauled into another state's courts by private plaintiffs unless they consent.

Impact

The decision gives states stronger sovereign immunity (protection from being sued without consent) in other states' courts. For example, a person usually cannot sue another state's tax agency in their home state's courts unless that state agrees.

Not official Court text.

Opinion documents