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Newsweek, Inc. v. Florida Dept. of Revenue

U.S.
Feb 23, 1998
522 U.S. 442 (1998)

Summary

In Newsweek and Reich, for example, this Court held that a state-court decision violated due process by robbing the taxpayer of a postpayment remedy that appeared available until the court ruled otherwise.

Summary of this case from Office of the United States Trustee v. John Q. Hammons Fall 2006, LLC

Opinion

No. 97-663.

Decided February 23, 1998


Effective January 1, 1988, Florida exempted newspapers, but not magazines, from its sales tax. See Fla. Stat. §§ 212.08(7)(w), 212.05(1)(i) (Supp. 1988). In 1990, the Florida Supreme Court found this classification invalid under the First Amendment of the Constitution of the United States. See Department of Revenue v. Magazine Publishers of America, Inc., 565 So.2d 1304 (1990), vacated and remanded, Miami Herald Publishing Co. v. Dept. of Revenue, 499 U.S. 972 (1991), reaff'd, 604 So.2d 459 (1992). In the wake of this ruling, Newsweek, a magazine, filed a claim for a refund of sales taxes it had paid between 1988 and 1990. See Fla. Stat. § 215.26(1) (Supp. 1998) ("The Comptroller of the state may refund . . . any moneys paid into the State Treasury").

When the Department of Revenue denied the refund, Newsweek filed suit, alleging the State's failure to accord it retroactive relief violated its due process rights under McKesson Corp. v. Division of Alcoholic Beverages and Tobacco, Fla. Dept. of Business Regulation, 496 U.S. 18 (1990). The Florida trial court granted summary judgment against Newsweek, and the District Court of Appeal affirmed. Although acknowledging McKesson's requirement of "meaningful backward-looking relief" when a taxpayer is forced to pay a tax before having an opportunity to establish its unconstitutionality, the District Court of Appeal held: " McKesson is distinguishable because that holding was expressly predicated upon the fact that the taxpayer had no meaningful predeprivation remedy." 689 So.2d 361, 363 (1997). The court interpreted Florida law to permit prepayment tax challenges by filing an action and paying the contested amount into the court registry, posting a bond, or obtaining a court order approving an alternative arrangement. See id., at 363-364 (citing Fla. Stat. § 72.011 (1987)). The court concluded Newsweek was afforded due process because it could have pursued this prepayment remedy without suffering onerous penalties. See 689 So.2d, at 364.

The District Court of Appeal's decision failed to consider our decision in Reich v. Collins, 513 U.S. 106 (1994). There, the Georgia Supreme Court had rejected a taxpayer's refund claim filed pursuant to a general refund statute, dismissing any due process concerns because a predeprivation remedy was available. See id., at 110. While assuming the constitutional adequacy of Georgia's predeprivation procedures, we nonetheless reversed because "no reasonable taxpayer would have thought that [the predeprivation procedures] represented, in light of the apparent applicability of the refund statute, the exclusive remedy for unlawful taxes." Id., at 111 (emphasis deleted). Until the Georgia Supreme Court's ruling, the taxpayer had no way of knowing from either the statutory language or case law that he could not pursue a postpayment refund and was relegated to a predeprivation remedy. See id., at 111-112. We emphasized a State "has the flexibility to maintain an exclusively predeprivation remedial scheme, so long as that scheme is `clear and certain.'" Id., at 110-111. But a State may not "bait and switch" by "hold[ing] out what plainly appears to be a `clear and certain' postdeprivation remedy and then declare, only after the disputed taxes have been paid, that no such remedy exists." Id., at 111, 108.

Under Florida law, there was a longstanding practice of permitting taxpayers to seek refunds under § 215.26 for taxes paid under an unconstitutional statute. See, e.g., State ex rel. Hardaway Contracting Co. v. Lee, 155 Fla. 724, 21 So.2d 211 (1945). At Florida's urging, federal courts have dismissed taxpayer challenges, including constitutional challenges, because § 215.26 appeared to provide an adequate postpayment remedy for refunds. See Tax Injunction Act, 28 U.S.C. § 1341 ("The district courts shall not enjoin . . . any tax under State law where a plain, speedy and efficient remedy may be had in the courts of such State"); see, e.g., Osceola v. Florida Dept. of Revenue, 893 F.2d 1231, 1233 (CA11 1990); Rendon v. State of Fla., 930 F. Supp. 601 (SD Fla. 1996). This Court, too, has interpreted Florida law to provide a postpayment remedy. See McKesson, supra, at 24, n. 4 ("It appears . . . Florida law does not require a taxpayer to pay under protest in order to preserve the right to challenge a remittance in a postpayment refund action"). The State does not dispute this settled understanding. The effect of the District Court of Appeal's decision below, however, was to cut off Newsweek's recourse to § 215.26. While Florida may be free to require taxpayers to litigate first and pay later, due process prevents it from applying this requirement to taxpayers, like Newsweek, who reasonably relied on the apparent availability of a postpayment refund when paying the tax.

Newsweek is entitled to a clear and certain remedy and thus it can use the refund procedures to adjudicate the merits of its claim. We grant the petition for a writ of certiorari, vacate the judgment, and remand the case for proceedings not inconsistent with this opinion.

It is so ordered.


Summaries of

Newsweek, Inc. v. Florida Dept. of Revenue

U.S.
Feb 23, 1998
522 U.S. 442 (1998)

In Newsweek and Reich, for example, this Court held that a state-court decision violated due process by robbing the taxpayer of a postpayment remedy that appeared available until the court ruled otherwise.

Summary of this case from Office of the United States Trustee v. John Q. Hammons Fall 2006, LLC

ordering that the petitioner must have access to Florida tax refund procedures

Summary of this case from U.S. Sales, Inc. v. Office of the United States Tr.

In Newsweek, Inc. v. Florida Department of Revenue, 522 U.S. 442, 118 S.Ct. 904, 139 L.Ed.2d 888 (1998), the Court again rejected the same argument based on the McKesson dicta and the availability of a predeprivation remedy.

Summary of this case from United Sates Tr. Region 21 v. Bast Amron LLP (In re Mosaic Mgmt. Grp.)

In Newsweek, the Florida Supreme Court had already held that Florida's exemption from its sales tax of newspapers but not magazines violated the Constitution.

Summary of this case from United Sates Tr. Region 21 v. Bast Amron LLP (In re Mosaic Mgmt. Grp.)

noting that the Florida court had denied refunds for the magazines

Summary of this case from United Sates Tr. Region 21 v. Bast Amron LLP (In re Mosaic Mgmt. Grp.)

requiring remedy for taxpayer who "reasonably relied on the apparent availability of a postpayment refund"

Summary of this case from Stone Container Corp. v. U.S.

noting that Court has interpreted section 215.26 as providing "a postpayment remedy"

Summary of this case from Department of Revenue v. Nemeth

In Newsweek, the Court did not mention any good-faith equitable exception. This substantiates my serious reservations as to the continued vitality of Gulesian under any circumstances. I believe the correct answer to the First District's certified question is that the Gulesian exception is not still valid.

Summary of this case from Dryden v. State

In Newsweek, 522 U.S. at 444, 118 S.Ct. 904, the Supreme Court held that a state could not engage in a “bait and switch” by holding out what appeared to be a clear and certain remedy, i.e., a tax appeal that could be pursued after paying disputed taxes, and then later declare that no such remedy exists.

Summary of this case from Gillette Commercial Operations N. American v. Dep't of Treasury

In Newsweek, 522 US at 444, the Supreme Court held that a state could not engage in a "bait and switch" by holding out what appeared to be a clear and certain remedy, i.e., a tax appeal that could be pursued after paying disputed taxes, and then later declare that no such remedy exists.

Summary of this case from Gillette Commercial Operations N. American v. Dep't of Treasury
Case details for

Newsweek, Inc. v. Florida Dept. of Revenue

Case Details

Full title:NEWSWEEK, INC. v . FLORIDA DEPARTMENT OF REVENUE ET AL. AJ ON PETITION FOR…

Court:U.S.

Date published: Feb 23, 1998

Citations

522 U.S. 442 (1998)

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