DaimlerChrysler Corp. v. Cuno

547 U.S. 332, 126 S. Ct. 1854 (2006)

 

RULE:

The standing inquiry requires careful judicial examination of a complaint's allegations to ascertain whether the particular plaintiff is entitled to an adjudication of the particular claims asserted. The United States Supreme Court has insisted, for instance, that a plaintiff must demonstrate standing separately for each form of relief sought. 

FACTS:

Under a contract with a city, defendant automobile manufacturer agreed to expand its local assembly plant in exchange for the city agreeing to waive the property tax for the plant. Because the manufacturer undertook to purchase and install new manufacturing machinery and equipment, it was also entitled to a credit against the state franchise tax. Most of the plaintiffs were residents of the city, who paid taxes to both the city and the State of Ohio. They claimed that they were injured because the tax breaks for the manufacturer diminished the funds available to the city and State, imposing a disproportionate burden on them. Plaintiff local taxpayers sued alleging that tax breaks for defendant automobile manufacturer violated the Commerce Clause. Defendant state and local officials and the automobile manufacturer sought certiorari to review the United States Court of Appeals' invalidation of a franchise tax credit, and the taxpayers sought certiorari to review the Court of Appeals' upholding of a property tax exemption. Certiorari was granted.

ISSUE:

Do Plaintiffs have state taxpayer standing to challenge the franchise tax credit?

ANSWER:

No.

CONCLUSION:

The Court held that: (1) it was unclear that the tax breaks did in fact deplete the treasury; (2) the taxpayers' alleged injury was conjectural or hypothetical in that it depended on how legislators responded; (3) the taxpayer's claims were no different from similar claims by federal taxpayers already rejected under U.S. Const. art. III as insufficient to establish standing; and (4) the taxpayers' Commerce Clausechallenge was not just like an Establishment Clause challenge. Plaintiffs failed to establish Article III injury with respect to their state taxes, and even if they did do so with respect to their municipal taxes, that injury does not entitle them to seek a remedy as to the state taxes.

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