## Facts

- Oklahoma enacted “third-structure” motor-carrier taxes aimed at vehicles registered in specified other States, designed to retaliate against allegedly discriminatory taxes imposed on Oklahoma-registered trucks.
- Out-of-state motor carrier taxpayers filed a class action in Oklahoma state court challenging the taxes under the dormant Commerce Clause and Article IV Privileges and Immunities, seeking declaratory and injunctive relief, refunds, and attorney’s fees under 42 U.S.C. §§ 1983 and 1988.
- The Oklahoma trial court upheld the taxes.
- The Oklahoma Supreme Court invalidated the taxes under the dormant Commerce Clause and ordered refunds under state law, but denied § 1983 equitable relief and § 1988 fees.
- After the U.S. Supreme Court recognized that dormant Commerce Clause violations can be actionable under § 1983, the case returned to the Oklahoma Supreme Court, which again denied § 1983 injunctive and declaratory relief (and thus § 1988 fees) because state law provided an adequate remedy (refunds) and federal policy disfavors equitable interference with state tax administration.
- The U.S. Supreme Court reviewed whether denying § 1983 equitable relief (and § 1988 fees) in this state tax context conflicted with federal law.

## Issues

1. Whether § 1983 requires or authorizes state courts to grant injunctive or declaratory relief against state taxes when state law provides an adequate legal remedy (such as a refund action).
2. Whether attorney’s fees under § 1988 are available when plaintiffs obtain relief only under state law and no relief is available under § 1983 in the circumstances.
3. Whether a state court’s refusal to provide § 1983 equitable relief (and § 1988 fees) in this context violates the Supremacy Clause.

## Decision

- The Supreme Court unanimously affirmed.
- Section 1983 provides no basis for courts to issue injunctive or declaratory relief in state tax cases when state law furnishes an adequate remedy at law.
- Because no relief could be awarded under § 1983 on these facts, attorney’s fees could not be awarded under § 1988.
- The state court’s denial of § 1983 equitable relief and § 1988 fees did not violate the Supremacy Clause.
- Justice Kennedy concurred in the judgment.

## Legal Principles

- Courts apply a longstanding noninterference principle in state tax administration; equitable relief against state tax collection is generally inappropriate where an adequate legal remedy exists.
- Although dormant Commerce Clause claims can be brought under § 1983, the availability of a § 1983 cause of action does not entail entitlement to injunctive or declaratory relief in state tax disputes with adequate state refund remedies.
- Section 1983 is construed in harmony with federal policy (reflected in limits on federal equitable intervention in state tax matters) against disrupting state tax systems when a plain, speedy, and efficient state remedy is available.
- Attorney’s fees under § 1988 are unavailable absent relief under § 1983; success solely under state-law refund procedures does not support a § 1988 fee award.

## Conclusion

The Court held that, in challenges to state taxation where state law provides an adequate refund remedy, § 1983 does not authorize injunctive or declaratory relief that would disrupt state tax administration, and without available § 1983 relief, § 1988 attorney’s fees cannot be awarded.


Nat’l Priv. Truck Council, Inc. v. Okla. Tax Comm’n, 515 U.S. 582 (1995)