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Franchise Tax Board of California v. Hyatt (2016)

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Franchise Tax Board of California v. Hyatt
Seal of the United States Supreme Court.svg
Argued December 7, 2015
Decided April 19, 2016
Full case nameFranchise Tax Board of California, Petitioner v. Gilbert P. Hyatt
Docket no. 14-1175
Citations578 U.S. 171 ( more )
136 S. Ct. 1277; 194 L. Ed. 2d 431
Holding
The Nevada rule not extending the same immunities to agencies of other states as it does to its own is a "policy of hostility" and unconstitutional under the Full Faith and Credit Clause.
Court membership
Chief Justice
John Roberts
Associate Justices
Anthony Kennedy  · Clarence Thomas
Ruth Bader Ginsburg  · Stephen Breyer
Samuel Alito  · Sonia Sotomayor
Elena Kagan
Case opinions
MajorityBreyer, joined by Kennedy, Ginsburg, Sotomayor, Kagan
ConcurrenceAlito (in judgment)
DissentRoberts, joined by Thomas

Franchise Tax Board of California v. Hyatt (short: Hyatt II), 578 U.S. 171 (2016), was a United States Supreme Court case in which the Court held that the Nevada rule that does not extend the same immunities to agencies of other states as it does to its own is effectively a "policy of hostility", which is unconstitutional under the Full Faith and Credit Clause. The Court split equally on the question whether Nevada v. Hall should be overruled, effectively upholding it. [1] [2] [3] [4]

Contents

Background

United States Supreme Court

The Supreme Court issued its opinion on April 19, 2016. [1] Writing for a 6-2 majority, Justice Breyer reasoned that the Supreme Court of Nevada's decision "applied a special rule of law applicable only in lawsuits against its sister States." Such a rule was unconstitutional under the Full Faith and Credit Clause.

Dissenting opnion

Chief Justice Robers wrote a dissenting opinion, joined by Justice Thomas. [1]

Subsequent developments

In 2019, in a majority opinion written by Justice Thomas, the Court expressly overruled Nevada v. Hall. [5]

References

  1. 1 2 3 "Franchise Tax Board of California v. Hyatt". Oyez. Retrieved May 15, 2020.
  2. "Franchise Tax Bd. of Cal. v. Hyatt, 578 U.S. ___ (2016)". Justia Law. Retrieved May 15, 2020.
  3. Gutoff, Jonathan M. (2017). "Franchise Tax Board of California v. Hyatt: A Split Court, Full Faith and Credit, and Federal Common Law". Roger Williams University Law Review. 22: 248.
  4. Hananel, Sam (April 20, 2016). "Tie leaves states facing lawsuits in other states". Reno Gazette-Journal.
  5. "Franchise Tax Board of California v. Hyatt, 587 U.S. ___ (2019)". Justia Law. Archived from the original on November 15, 2025. Retrieved February 17, 2026.
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