CSX Transportation, Inc. v. Alabama Department of Revenue
2011 United States Supreme Court case
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CSX Transp., Inc. v. Ala. Dept. of Revenue, 562 U.S. 277 (2011), was a United States Supreme Court case in which the court held that a railroad can challenge state's sales and use taxes as discriminatory under the Railroad Revitalization and Regulatory Reform Act of 1976 when the tax in question is imposed on railroads but not their main competitors.[1][2]
| CSX Transp., Inc. v. Ala. Dept. of Revenue | |
|---|---|
 | |
| Decided February 22, 2011 | |
| Full case name | CSX Transportation, Inc. v. Alabama Department of Revenue |
| Citations | 562 U.S. 277 (more) |
| Holding | |
| A railroad can challenge state's sales and use taxes as discriminatory under the Railroad Revitalization and Regulatory Reform Act of 1976 when the tax in question is imposed on railroads but not their main competitors | |
| Court membership | |
| |
| Case opinions | |
| Majority | Kagan, joined by Roberts, Scalia, Kennedy, Breyer, Alito, Sotomayor |
| Dissent | Thomas, joined by Ginsburg |
| Laws applied | |
| Railroad Revitalization and Regulatory Reform Act of 1976 | |
Background
CSX is an interstate rail carrier that operates, and pays taxes, in Alabama. Alabama imposes sales and use taxes on railroads when they purchase or consume diesel fuel, but exempts their main competitors—interstate motor and water carriers. CSX sued the Alabama Department of Revenue and its Commissioner (Alabama), claiming that this tax scheme discriminates against railroads in violation of the Railroad Revitalization and Regulatory Reform Act of 1976 (4–R Act), which bars four forms of discriminatory taxation in 49 U.S.C. §11501(b). Three of the delineated prohibitions deal with property taxes, and the fourth is a catch-all provision that forbids a State to "[i]mpose another tax that discriminates against a rail carrier". The federal District Court dismissed CSX's suit as not cognizable under the 4–R Act on the basis of the Supreme Court's decision in Department of Revenue of Ore. v. ACF Industries, Inc., 510 U. S. 332, and the Eleventh Circuit Court of Appeals affirmed.[1]
Opinion of the court
The Supreme Court issued an opinion on February 22, 2011.[1]
Later developments
In 2015, the case returned to the Supreme Court in Alabama Department of Revenue v. CSX Transportation, Inc..
