Franchise Tax Board v. Construction Laborers Vacation Trust case brief
Franchise Tax Board v. Construction Laborers Vacation Trust case
463 U.S. 1 (1983)
Appellant state tax board sought review
of an order from the United States Court of Appeals for the Ninth
Circuit, which denied appellant's petition for rehearing, in
appellant's state-law action against appellee trust for a declaratory
judgment as to its rights to levy on assets in an employee welfare
benefit plan subject to the Employee Retirement Income Security Act
of 1974 (ERISA), 29 U.S.C.S. §§ 1001 et seq.
CASE FACTS Appellant state tax board filed a
state-court declaratory judgment action against appellee trust that
sought a ruling as to appellant's rights in assets held by respondent
in an employee welfare benefit plan, which was subject to the
Employee Retirement Income Security Act of 1974 (ERISA), 29
U.S.C.S. §§ 1001 et seq., and which appellee removed to federal
Holding that no federal-question jurisdiction existed, the
court vacated the judgment and instructed that it be remanded to the
The court held that as to federal question jurisdiction,
Congress gave federal courts jurisdiction to hear only those cases in
which a well-pleaded complaint established either that federal law
created the cause of action or that the plaintiff's right to relief
necessarily depended on resolution of a substantial question of
The court held that ERISA created no counterpart to
appellant's state-law claims and thus had not pre-empted the causes
of action -- even if ERISA precluded enforcement of the claims.
court also held that appellant's claims did not turn on a question of
federal law such that federal courts would take
The court vacated the judgment for appellee trust and remanded for
disposition by the state court, because under the "well-pleaded
complaint" rule, appellant's action to levy against the plan
assets or for a declaration of rights was neither created by ERISA
nor turned on a substantial question of federal law, and thus could
not be removed to federal court. Recommended Supplements for Civil Procedure
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