« PředchozíPokračovat »
Respondents correctly note that, since Cohens, the effect of the Eleventh Amendment on this Court's appellate jurisdiction over cases arising in state court has only infrequently been discussed in our cases. But those discussions uniformly reveal an understanding that the Amendment does not circumscribe our appellate review of state-court judgments.' Moreover, that this Court has had little occasion to discuss the issue merely reflects the extent to which States, though frequently interjecting Eleventh Amendment objections to suits initiated against them in federal court, have understood the time-honored practice of appellate review of state-court judgments to be consistent with this Court's role in our federal system. “[I]t is plain that the framers of the constitution did contemplate that cases within the judicial cognizance of the United States not only might but would arise in the state courts, in the exercise of their ordinary jurisdiction.” Martin v. Hunter's Lessee, 1 Wheat. 304, 340 (1816).10 To
707 (1981) (reversing state-court decision against claimant in suit against state entity seeking payment of unemployment benefits); Bonelli Cattle Co. v. Arizona, 414 U. S. 313 (1973) (reversing state-court decision against claimant in suit against State seeking to quiet title).
'In several recent cases, we have exercised appellate jurisdiction to review issues of federal law arising in suits brought against States or state entities in state court even after noting that the Eleventh Amendment would have precluded federal jurisdiction as an original matter. See, e. g., Will v. Michigan Dept. of State Police, 491 U. S. 58, 65, n. 5 (1989) (“Had the present § 1983 action been brought in federal court,” the District Court would have “dismissed the plaintiff's damages claim as barred by the Eleventh Amendment”); Maine v. Thiboutot, 448 U. S. 1, 9, n. 7 (1980) (“[N]o Eleventh Amendment question is present, of course, where an action is brought in a state court"); cf. Nevada v. Hall, 440 U. S. 410, 420 (1979) (exercising appellate jurisdiction over action brought in state court against State but noting that the Eleventh Amendment “places explicit limits on the powers of federal courts to entertain suits against a State”).
1° See also Tafflin v. Levitt, 493 U. S. 455, 458 (1990) (“[S]tate courts have inherent authority, and are thus presumptively competent, to adjudicate claims arising under the laws of the United States"); The Federalist No. 82, p. 555 (J. Cooke ed. 1961) (A. Hamilton) (“[I]n every case in which [state courts) were not expressly excluded by the future acts of the national legislature, they will of course take cognizance of the causes to which
secure state-court compliance with, and national uniformity of, federal law, the exercise of jurisdiction by state courts over cases encompassing issues of federal law is subject to two conditions: State courts must interpret and enforce faithfully the “supreme Law of the Land," 11 and their decisions are subject to review by this Court.2 Whereas the Eleventh
those acts may give birth. ... [T]he inference seems to be conclusive that the state courts would have a concurrent jurisdiction in all cases arising under the laws of the union, where it was not expressly prohibited”).
11 “This Constitution, and the Laws of the United States which shall be made in Pursuance thereof; and all Treaties made, or which shall be made, under the Authority of the United States, shall be the supreme Law of the Land; and the Judges in every State shall be bound thereby, any Thing in the Constitution or Laws of any state to the contrary notwithstanding." U. S. Const., Art. VI.
12 “Upon the State courts, equally with the courts of the Union, rests the obligation to guard, enforce, and protect every right granted or secured by the Constitution of the United States and the laws made in pursuance thereof, whenever those rights are involved in any suit or proceeding before them .... If they fail therein, and withhold or deny rights, privileges, or immunities secured by the Constitution and laws of the United States, the party aggrieved may bring the case from the highest court of the State in which the question could be decided to this court for final and conclusive determination.” Robb v. Connolly, 111 U. S. 624, 637 (1884). See also Brinkerhoff-Faris Trust & Savings Co. v. Hill, 281 U. S. 673, 681 (1930) (“[T]he plaintiff's claim is one arising under the Federal Constitution and, consequently, one on which the opinion of the state court is not final”); Martin v. Hunter's Lessee, 1 Wheat. 304, 347–348 (1816) (plenary appellate jurisdiction of Supreme Court motivated in part by “the importance, and even necessity of uniformity of decisions throughout the whole United States, upon all subjects within the purview of the constitution”). In Atascadero State Hospital v. Scanlon, 473 U. S. 234 (1985), the Court responded to the dissent's concern that state courts might inadequately protect federal rights despite the Supremacy Clause by adverting to the dissent's description, id., at 256, n. 8, of a “longstanding, though unarticulated, rule that the Eleventh Amendment does not limit exercise of otherwise proper federal appellate jurisdiction over suits (against States] from state courts.” Id., at 240, n. 2.
Of course, though the Eleventh Amendment does not constrain this Court's appellate jurisdiction over such suits, appellate jurisdiction may be constrained for other reasons not apposite here. For example, a statecourt judgment would be unreviewable were it to rest on an independent
Amendment has been construed so that a State retains immunity from original suit in federal court, see Atascadero State Hospital v. Scanlon, 473 U. S. 234, 237–240 (1985), it is "inherent in the constitutional plan,” Monaco v. Mississippi, 292 U. S. 313, 329 (1934), that when a state court takes cognizance of a case, the State assents to appellate review by this Court of the federal issues raised in the case "whoever may be the parties to the original suit, whether private persons, or the state itself.” 13 We recognize what has long been im
and adequate state-law ground. See Michigan v. Long, 463 U. S. 1032, 1038, n. 4 (1983).
13 Charles River Bridge v. Warren Bridge, 11 Pet. 420, 585 (1837) (Story, J., dissenting), citing Cohens v. Virginia, 6 Wheat. 264 (1821).
For example, in Smith v. Reeves, 178 U. S. 436 (1900), the Court dismissed a suit brought in federal court by an aggrieved taxpayer seeking a refund for a State's illegal assessment. We explained, however, that the State's decision to consent to suit only in state, but not federal, court is “subject always to the condition, arising out of the supremacy of the Constitution of the United States and the laws made in pursuance thereof, that the final judgment of the highest court of the State in any action brought against it with its consent may be reviewed or reexamined [by this Court), as prescribed by the act of Congress, if it denies to the plaintiff any right, title, privilege or immunity secured to him and specially claimed under the Constitution or laws of the United States.” Id., at 445.
Similarly, in Chandler v. Dix, 194 U. S. 590 (1904), the Court dismissed a quiet title suit brought in federal court by a citizen with respect to lands that had been taken by a State and sold to recoup compensation for certain tax deficiencies. The Court found that the State was a necessary party defendant and that the Eleventh Amendment barred initiation of the suit in federal court. The Court simultaneously declared, however, that “[o]f course, a taxpayer denied rights secured to him by the Constitution and laws of the United States, and specially set up by him, could bring the case here [to the Supreme Court] by writ of error from the highest courts of the State.” Id., at 592. See also Rosewell v. LaSalle National Bank, 450 U. S. 503, 515-516, n. 19 (1981) (under state tax refund scheme, "a taxpayer may raise all constitutional objections, including those based on the State's failure to pay interest or to return all unconstitutionally collected taxes, in the [state] legal refund proceeding, . . . after which the litigants have an opportunity to seek review in this Court”).
plicit in our consistent practice and uniformly endorsed in our cases: The Eleventh Amendment does not constrain the appellate jurisdiction of the Supreme Court over cases arising from state courts. Accordingly, we turn to the merits of petitioner's claim.
III It is undisputed that the Florida Supreme Court, after holding that the Liquor Tax unconstitutionally discriminated against interstate commerce because of its preferences for liquor made from “crops which Florida is adapted to growing,”” 524 So. 2d, at 1008, acted correctly in awarding petitioner declaratory and injunctive relief against continued enforcement of the discriminatory provisions. The question before us is whether prospective relief, by itself, exhausts the requirements of federal law. The answer is no: If a State places a taxpayer under duress promptly to pay a tax when due and relegates him to a postpayment refund action in which he can challenge the tax's legality, the Due Process Clause of the Fourteenth Amendment 14 obligates the State to provide meaningful backward-looking relief to rectify any unconstitutional deprivation. 15
14 “[N]or shall any State deprive any person of life, liberty, or property, without due process of law.” U. S. Const., Amdt. 14, § 1.
15 Respondents do not question the Florida Supreme Court's holding that the Liquor Tax violated the Commerce Clause. And it is clear that, under the approaches advanced today in American Trucking Assns., Inc. v. Smith, post, p. 167, the Florida Supreme Court's holding governs the validity of respondents' taxation of petitioner prior to the date of the court's decision. Under JUSTICE O'CONNOR's approach, see post, at 177–178, the Florida court's decision applies retroactively because it rested on established principles of Commerce Clause jurisprudence. See infra, at 45–46. Under JUSTICE STEVENS' approach, post, at 212–218, the Florida court's decision, like all judicial decisions, applies retroactively. See also JUSTICE SCALIA's separate opinion, post, at 204–205; the circumstances present in that case warranting in his view a departure from stare decisis are not present here.
A We have not had occasion in recent years to explain the scope of a State's obligation to provide retrospective relief as part of its postdeprivation procedure in cases such as this. 16 Our approach today, however, is rooted firmly in precedent dating back to at least early this century. Atchison, T. & S. F. R. Co. v. O'Connor, 223 U. S. 280 (1912), involved a suit by a railroad company to recover taxes it had paid under protest, alleging that the tax scheme violated the Commerce Clause because most of the franchise tax was apportioned to business conducted wholly outside the State. The Court agreed that the franchise tax was unconstitutional and concluded that the railroad company was entitled to a refund of the portion of the tax imposed on out-of-state activity. Justice Holmes explained:
“It is reasonable that a man who denies the legality of a tax should have a clear and certain remedy. The rule being established that apart from special circumstances he cannot interfere by injunction with the State's collection of its revenues, an action at law to recover back what he has paid is the alternative left. Of course we are speaking of those cases where the State is not put to an action if the citizen refuses to pay. In these latter he can interpose his objections by way of defence, but when, as is common, the State has a more summary remedy, such as distress, and the party indicates by protest that he is yielding to what he cannot prevent, courts sometimes perhaps have been a little too slow to recognize the implied duress under which payment is made.
16 In the recent past, after invalidating a state tax scheme on Commerce Clause grounds, we have left state courts with the initial duty upon remand of crafting appropriate relief in accord with both federal and state law. See, e. g., American Trucking Assns., Inc. v. Scheiner, 483 U. S. 266, 297–298 (1987); Tyler Pipe Industries, Inc. v. Washington State Dept. of Revenue, 483 U. S., at 251-253; Williams v. Vermont, 472 U. S., at 28; Bacchus Imports, 468 U. S., at 277.