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Richards v. Jefferson County

United States Supreme Court
517 U.S. 793 (1996)


Jefferson County, Alabama (the county) (defendant) passed an occupation tax. The City of Birmingham and its finance director sued to challenge the tax. That suit was consolidated with an action by three taxpayers. The Alabama Supreme Court upheld the tax. Bedingfield v. Jefferson County, 527 So.2d 1270 (1988). Subsequently, Jason Richards and Fannie Hill (plaintiffs) sued in federal court to challenge the tax. That suit was dismissed under the Tax Injunction Act, 28 U.S.C. § 1341. The plaintiffs refiled in Alabama circuit court on behalf of a class of all similarly situated county taxpayers, arguing that the tax violated the Due Process and Equal Protection Clauses of the Constitution, as well as Alabama constitutional provisions. The trial court granted summary judgment to the county on the state law claims, but not the federal ones, based on its conclusion that the state law claims were precluded by the Bedingfield decision. The county appealed, and the Alabama Supreme Court held that all of the claims were precluded, because the Bedingfield taxpayers adequately represented the plaintiffs. The plaintiffs petitioned the United States Supreme Court for certiorari, which was granted.

Rule of Law


Holding and Reasoning (Stevens, J.)

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