Grable & Sons Metal Products Inc. v. Darue Engineering and Manufacturing
125 S. Ct. 2363 (2005)

  • Beginning in 1988, Grable & Sons Metal Products, Inc. did not pay corporate income taxes six years in a row.
    • Sticking it to the man!
  • Finally, in 1994, the IRS seized Grable’s property in Michigan to pay the debt. But instead of hand-delivering the notice of seizure to Grable, as IRS regulations require, they sent it certified mail.
    • Grable received the notice and did not argue when the IRS took the property, or when the land was later sold to Darue.
  • Six years after that, Grable sued Darue in a Michigan State Court.
    • Grable claimed that the IRS seizure and sale of the land were invalid because no one personally handed over the notice.
  • Darue moved the case to Federal Court.
    • There are three ways to get a case heard before a Federal Court:
      • A conflict between parties in two different States,
        • aka diversity jurisdiction.
      • A question regarding the United States Constitution, or
        • aka a federal question.
      • A question regarding the Federal laws of the United States.
    • In this case, Darue argued that the case turned on the wording of the IRS code, making it a federal question. Therefore the Federal Court had proper jurisdiction.
  • Grable asked to be moved back to the State Court, claiming the Federal Court didn’t have the authority to hear the case. Federal Trial Court denied the motion. Grable appealed.
    • Grable argued that a violation of a Federal law doesn’t necessarily make it a substantial federal interest. Although the case originated in Federal tax law, Grable’s lawsuit was between two private Michigan residents about some property in Michigan. It had nothing to do with the Federal government, so it wasn’t a federal question and there was no diversity jurisdiction so it shouldn’t be heard in a Federal court.
  • The Federal Appellate Court affirmed. Grable appealed.
  • Federal Appellate Court affirmed. Grable appealed.
  • US Supreme Court affirmed.
    • The US Supreme Court found that the national interest in providing a federal forum for such tax litigation is sufficiently substantial to support the exercise of federal question jurisdiction.