Brief Fact Summary.
State tax authorities sought to collect on unpaid income taxes by levying on funds in the Construction Laborers Vacation Trust.
Synopsis of Rule of Law.
Federal court may only issue judgment on cases that create a complaint that arises under federal law or a question of federal law needs to be resolved.
A complaint for declaratory relief is legally sufficient if it sets forth facts showing the existence of an actual controversy relating to the legal rights and duties of the respective parties under a written instrument and requests that these rights and duties be adjudged by the court.
View Full Point of LawThe Construction Laborers Vacation Trust (CLVT) was created to fund annual paid vacations for members of the union. Three union members did not pay their state income taxes and the state sought the unpaid funds through the CLVT.
Issue.
Whether a federal court maintains jurisdiction under 28 USC § 1331?
Held.
No. 28 USC § 1331 allows federal courts to hear cases whose subject matter are within the Constitution, laws, and treaties of the United States.