545 U.S. 308
-Petitioner, a former owner sued respondent quitclaim deed holder, alleging that the record title was invalid because the IRS failed to notify it of a seizure as required by statute.
-The Sixth Circuit Court affirmed the denial of the owner's motion to remand.
-The court granted ertiorari as to the issue of whether a federal cause of action was always required to exercise federal question jurisdiction.
ISSUE: To determine whether federal-question jurisdiction exists over federal issues that are embedded in state-law claims between non-diverse parties, the question exists: whether the state-law claim necessarily raises a stated federal issue, which is either disputed and substantial, which a federal forum could entertain without disturbing any congressionally approved balance of federal and state judicial responsibilities.
This case warranted federal jurisdiction because the owner's claim was premised on the IRS's failure to give adequate notice under federal law.
ANALYSIS:Whether notice was given under meaning of the statute was an essential element of the claim of quiet title.
The meaning of the federal statute was in dispute.
The meaning of the statute belonged in federal court due to the government's strong interest in collecting taxes.
Existing precedent, when read in its entirety, treats the absence of a federal private right of action as evidence that is relevant to (however, not dispositive of) the judgments about congressional intent that is required under the statute.
OUTCOME: The lower court's judgment, which affirmed the existence of federal jurisdiction over the owner's quiet title action, was affirmed.
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