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

377 F.3d 592 (2004)

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

United States Court of Appeals for the Sixth Circuit
377 F.3d 592 (2004)

Facts

In 1994, the Internal Revenue Service (IRS) seized the property of Grable & Sons Metal Products, Inc. (Grable) (plaintiff) due to Grable’s unpaid taxes. Although Internal Revenue Code (code) § 6335(a) required the IRS to personally notify Grable about the seizure, the IRS notified Grable by certified mail, which Grable received. The IRS sold the property to Darue Engineering & Manufacturing (Darue) (defendant) in December 1994. In December 2000, Grable brought a state-court quiet-title suit challenging the sale on the ground that the IRS failed to strictly comply with § 6335(a). Darue removed the case to federal court on federal-question-jurisdiction grounds. Grable moved to remand the case to state court, contending that federal-question jurisdiction was lacking. The district court denied remand and ultimately awarded summary judgment to Darue. Grable appealed. In addition to reiterating the alleged lack of federal-question jurisdiction, Grable contended that it was irrelevant that code § 6339(b)(2) provided that a tax sale was valid even if the IRS only substantially complied with “provisions of law” because (1) permitting substantial compliance would negate § 6335(a)’s notice requirements and (2) “provisions of law” referred to state law.

Rule of Law

Issue

Holding and Reasoning (Boggs, C.J.)

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Casebooks

Tax Practice and Procedure

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