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Grable & Sons Metal Products, Inc. v. Darue Engineering & Manufacturing

United States Supreme Court
545 U.S. 308 (2005)


Facts

In 1994, the Internal Revenue Service (IRS) seized Michigan real property belonging to Grable & Sons Metal Products, Inc. (Grable) (plaintiff) to satisfy federal back taxes Grable owed to the IRS. After giving Grable the statutorily guaranteed notice of the upcoming sale via certified mail, the IRS sold the property to Darue Engineering and Manufacturing (Darue) (defendant). Five years after the sale, Grable filed a motion to quiet title in state court, alleging that he did not receive proper notice of the sale because he was not personally served in the manner required by 26 U.S.C. §6335, but rather received notice via certified mail. Darue removed the action to federal court, arguing that the case presented a federal question, because it required interpretation of a federal tax law. The district court found that the federal jurisdiction was appropriate, and the United States Court of Appeals for the Sixth Circuit affirmed. The United States Supreme Court granted certiorari on the jurisdictional question.

Rule of Law

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Issue

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Holding and Reasoning (Souter, J.)

The holding and reasoning section includes:

  • A “yes” or “no” answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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