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

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
Docket activity
New analysis added
AI analysis generated: Case Briefing
New analysis added
New analysis added
New analysis added
Show 7 moreShow fewer
New analysis added
New analysis added
New analysis added
New analysis added
New analysis added
New analysis added
New analysis added
More questions
- 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.