Montana v. United States case brief

Montana v. United States case brief summary
440 U.S. 147 (1979)

CASE SYNOPSIS

Appellant, the State of Montana, challenged a judgment of the United States District Court for the District of Montana, which held that the United States was not bound by a decision of the Montana Supreme Court and struck down a state gross receipts tax, Mont. Rev. Code Ann. § 84-3505 (Supp. 1977), as violative of the Supremacy Clause.

DISCUSSION

• The Supreme Court reversed the judgment on grounds of collateral estoppel without reaching the merits because it found that the constitutional question presented by the instant appeal had been determined adversely to the United States in a prior state proceeding. 
• The Court found that although not a party, the United States plainly had a sufficient "laboring oar" in the conduct of state-court litigation to actuate principles of estoppel. 
• The Court found that collateral estoppel was appropriate because the issues presented by the instant litigation were in substance the same as those resolved against the United States in the state court decision; controlling facts and legal principles had not changed significantly since the state-court judgment; and there were no special circumstances to warrant an exception to the normal rules of preclusion.

CONCLUSION
The Court reversed a judgment finding that appellant's gross receipts tax discriminated against the United States in violation of the Supremacy Clause on grounds of collateral estoppel without reaching the merits.


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