Franchise Tax Board of California v. Hyatt

Supreme Court of the United States · 2019 · Federal Courts

Federal Courtsstate sovereign immunityinterstate immunitysister-state courtsNevada v. Hall overruledconstitutional structureEleventh Amendmentfederalism

Facts

Gilbert Hyatt claimed to have moved from California to Nevada in 1991 and filed tax returns listing Nevada as his primary residence. The California Franchise Tax Board suspected the move was a sham, audited him, sent employees to Nevada, and allegedly committed tortious acts there while investigating his residency. Hyatt sued the Board in Nevada state court in 1998 for those alleged torts. The Board asserted immunity from suit, and the case ultimately presented whether California could be sued without consent in Nevada's courts.

Issue

Does the Constitution permit a State to be sued by a private party, without its consent, in the courts of another State? More specifically, should Nevada v. Hall, which allowed such suits, be overruled?

Rule

States retain their sovereign immunity from private suits brought in the courts of other States. The Constitution embeds interstate sovereign immunity in its structure and historical understanding, so a nonconsenting State may not be haled into a sister State's courts by a private party.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Nina Morales, a resident of Oregon, sued the State of Idaho in an Oregon state court for damages after Idaho transportation officials allegedly trespassed on her land during a bridge survey near the border. Idaho has not consented to suit in Oregon.

Should the Oregon court exercise jurisdiction over Idaho?

Explanation. The majority held that States retain sovereign immunity from private suits brought in the courts of other States. That immunity is embedded in the Constitution's structure and historical understanding, not left to the forum State's discretionary comity. So Oregon cannot hale nonconsenting Idaho into its courts.