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verification. (August 2017) |
Grable & Sons Metal Products, Inc. v. Darue Engineering & Mfg. | |
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Argued April 18, 2005 Decided June 13, 2005 | |
Full case name | Grable & Sons Metal Products, Inc. v. Darue Engineering & Mfg. |
Citations | 545
U.S.
308 (
more) 125 S. Ct. 2363; 162
L. Ed. 2d 257; 2005
U.S. LEXIS 4659 |
Case history | |
Prior | 207 F. Supp. 2d 694 ( W.D. Mich. 2002); affirmed, 377 F.3d 592 ( 6th Cir. 2004); cert. granted, 543 U.S. 1042 (2005). |
Subsequent | Rehearing denied, 545 U.S. 1158 (2005). |
Holding | |
That the national interest in providing a federal forum for federal tax litigation is sufficiently substantial to support the exercise of federal-question jurisdiction over the disputed issue on removal. | |
Court membership | |
| |
Case opinions | |
Majority | Souter, joined by unanimous |
Concurrence | Thomas |
Laws applied | |
28 U.S.C. § 1331 |
Grable & Sons Metal Products, Inc. v. Darue Engineering & Mfg., 545 U.S. 308 (2005), was a United States Supreme Court decision [1] involving the jurisdiction of the federal district courts under 28 U.S.C. § 1331 (federal question jurisdiction). [2]
In 1994, the Internal Revenue Service seized real property belonging to Grable & Sons Metal Products, Inc., to satisfy Grable's federal tax delinquency. The IRS sent notice of the tax sale by certified mail. At the tax sale the IRS sold the property to Darue Engineering and Manufacturing. Grable later brought a quiet title action in state court, alleging that the IRS sale was invalid. Grable argued that, under 26 U.S.C. § 6335, the IRS was required to give notice to Grable by personal service, not certified mail. Darue attempted to remove the case to Federal District Court. Darue argued that the federal district court had jurisdiction, because the claim of title depended on the interpretation of the notice statute in the federal tax law.
The question raised was whether the federal district courts have original federal question jurisdiction under 28 U.S.C. § 1331 when a claim arises out of a federal statute that has not specifically granted a private right to a cause of action.
The Court affirmed the Sixth Circuit and ruled that there was federal question jurisdiction.
Justice Souter, writing for a unanimous court, held that the federal court had jurisdiction for the following reasons: