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Franchise Tax Board v. Hyatt

United States Supreme Court
139 S. Ct. 1485 (2019)


Facts

Gilbert Hyatt (plaintiff) earned millions from a computer-chip patent. Before receiving the patent, Hyatt lived in California, which collects personal income tax. In 1991 Hyatt sold his house in California and rented an apartment and registered to vote in Nevada—which collects no personal income tax—and then filed his 1991 and 1992 taxes claiming Nevada residency. California’s Franchise Tax Board (the board) (defendant) was suspicious of Hyatt’s move and conducted an audit. Board employees interviewed estranged family members, shared personal information about Hyatt with business contacts, and sent over 100 letters requesting information from third parties. The board concluded Hyatt did not move to Nevada until 1992 and owed over $10 million in back taxes. After an 11-year proceeding, the board upheld the award. Meanwhile, Hyatt sued the board in Nevada state court for torts allegedly committed during the audit. The board argued California was immune from suit, but in Hyatt I the Supreme Court found the board entitled to the same immunity as Nevada agencies—from negligent but not intentional torts. On remand, the jury awarded Hyatt over $490 million. But in Hyatt II, the Supreme Court ruled Nevada’s $50,000 damages cap applied. The board appealed a third time on sovereign-immunity grounds.

Rule of Law

Issue

Holding and Reasoning (Thomas, J.)

Dissent (Breyer, J.)

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