Franchise Tax Board of California v. Hyatt

Franchise Tax Bd. of Cal. v. Hyatt
Supreme Court of the United States
Argued January 9, 2019 Decided May 13, 2019
Full case name	Franchise Tax Board of California, Petitioner v. Gilbert P. Hyatt
Docket no.	17-1299
Citations	587cac U.S. ___ (more) 139 S. Ct. 1485 203 L. Ed. 2d 768
Argument	Oral argument
Decision	Opinion
Case history
Prior	538 U.S. 488 (2003) 335 P.3d 125 (2014) 578 U.S. ___,   136 S. Ct. 1277 (2016) 407 P. 3d 717 (2017)
Holding
States have sovereign immunity from private suits against them in courts of other states without their consent. Judgement of the Nevada Supreme Court reversed and remanded.
Court membership
Chief Justice John Roberts Associate Justices Clarence Thomas · Ruth Bader Ginsburg Stephen Breyer · Samuel Alito Sonia Sotomayor · Elena Kagan Neil Gorsuch · Brett Kavanaugh
Case opinions
Majority	Thomas, joined by Roberts, Alito, Gorsuch, Kavanaugh
Dissent	Breyer, joined by Ginsburg, Sotomayor, Kagan
Laws applied
U.S. Const. Amend. XI
This case overturned a previous ruling or rulings
Nevada v. Hall (1979)

Franchise Tax Board of California v. Hyatt (short: Franchise Tax Bd. of Cal. v. Hyatt or Hyatt III),^[1] 587 U.S. ___ (2019), was a United States Supreme Court case that determined that unless they consent, states have sovereign immunity from private suits filed against them in the courts of another state. The 5–4 decision overturned precedent set in a 1979 Supreme Court case, Nevada v. Hall. This was the third time that the litigants had presented their case to the Court, as the Court had already ruled on the issue in 2003 and 2016.

The ruling ended a long tax dispute between Gilbert Hyatt and California regarding alleged tax fraud by Hyatt. Hyatt had been challenging the tax fraud penalties that the California Franchise Tax Board (FTB) had ordered him to pay since 1993, both in court and through administrative proceedings. Because of the Supreme Court ruling, Hyatt was required to pay for all legal costs he incurred, without receiving a judgement against the FTB. On this matter, Justice Clarence Thomas wrote: "The consequences for the inventor are that he'll suffer the loss of two decades of litigation expenses and a final judgment against the Board for its egregious conduct. ... Those case-specific costs are not among the reliance interests that would persuade us to adhere to an incorrect resolution of an important constitutional question."

Justice Stephen Breyer, in the dissenting opinion, warned of the willingness of the majority to overrule precedent, saying, "To overrule a sound decision like Hall ... is to cause the public to become increasingly uncertain about which cases the court will overrule and which cases are here to stay", referencing as an example Planned Parenthood v. Casey, a 1992 case that affirmed the landmark abortion rights case Roe v. Wade. As a result of this ruling, Gilbert Hyatt did not receive $100,000 in damages from California. Although he was originally granted $389 million in damages by a Nevada jury, rulings by the Nevada Supreme Court and the U.S. Supreme Court reduced the amount to $100,000.