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Hibbs v. Winn

542 U.S. 88 (2004)

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Hibbs v. Winn

United States Supreme Court

542 U.S. 88 (2004)

Facts

An Arizona statute allowed taxpayers to claim a tax credit of up to $625 for donating money to a school-tuition organization (STO). STOs were nonprofit organizations that provided scholarships to children attending private schools. Nonprofits that provided scholarships to students based on a religion preference qualified as STOs. The tax credits did not cost the taxpayer because the taxpayer could elect to donate up to $625 to an STO or pay the $625 to the Arizona Department of Revenue as taxes. Kathleen Winn (plaintiff), an Arizona taxpayer, sued J. Elliott Hibbs (the Director) (defendant), the director of the Arizona Department of Revenue, under 42 U.S.C. § 1983, alleging that the Arizona statute violated the Establishment Clause. Winn did not contest her own tax liability. Instead, Winn asked the district court for injunctive and declaratory relief to prevent the tax credit’s imposition due to its unconstitutionality. The Director moved to dismiss the complaint, arguing that the Tax Injunction Act (TIA) prohibited federal courts from hearing state tax matters. Due to the TIA, the district court dismissed the action. The court of appeals reversed. The Supreme Court granted certiorari to determine whether the TIA barred constitutional challenges to state tax credits in federal court.

Rule of Law

Issue

Holding and Reasoning (Ginsburg, J.)

Concurrence (Stevens, J.)

Dissent (Kennedy, J.)

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