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Wis. Dep't of Revenue v. Union Pac. R.R.

Updated Sep 20, 2026

In brief

The Supreme Court refused to hear the case, so it did not rule on the 4-R Act question.

Where it stands
Decided

Decided · May 4, 2020

What it’s about
The Court held that the 4-R Act does not let a railroad prove tax discrimination by comparing itself only with a selected group of exempt competitors.
Who it affects
The order ends Supreme Court review for Wisconsin and Union Pacific but leaves their tax-discrimination dispute unresolved.

Summary: written with AI from the case record.

Illustration for Wis. Dep't of Revenue v. Union Pac. R.R. Co.
Conceptual illustration · AI-generated

What it's about

Instead, the railroad generally must show that the state tax treats it worse than the broader class of commercial and industrial taxpayers; the Court vacated the Seventh Circuit’s ruling favoring Union Pacific and sent the case back for further proceedings.

The case came from the Seventh Circuit and concerned how the federal 4-R Act tests state taxes that may discriminate against railroads.

Question presented

Whether the 4-R Act, 49 U.S.C. § 11501(b)(4), which prohibits a state from imposing "another tax that discriminates against a rail carrier," allows a railroad to challenge a generally applicable tax by comparing itself to a hand-picked group of "competitors" that are exempt from the tax, or whether the railroad must instead show that the tax discriminates against it as compared to other commercial and industrial taxpayers.

What the Court decided

Holding

Petition DENIED.

What's next

The Supreme Court docket action is finished. The record does not identify what happens next in the lower courts.

Documents

3

Docket activity

24
  • New analysis added

    Sep 20, 2026 · Court records

  • AI analysis generated: Case Briefing

    Sep 20, 2026 · Generated

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    Sep 19, 2026 · Court records

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Older entries are on the full docket.

More questions

1
What does a denied petition mean in this case?
It means the Supreme Court refused to hear the case; the order was not a ruling for Wisconsin or Union Pacific.

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.

Checked Sep 20, 2026Methodology

Court records and filings

Reporting and analysis