Conflicts Keyed to Currie
Grable & Sons Metal Products, Inc., Petitioner v. Darue Engineering & Manufacturing
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The IRS seized property in 1994 owned by Grable (Plaintiff) to satisfy an outstanding federal tax bill. Darue (Defendant) then purchased the property at a federal tax sale and received a quitclaim deed from the federal government. Five years later, Plaintiff brought a quiet title action in state court against Defendant claiming that the IRS failed to follow the precise statutory mandate for notification of the seizure of property. Plaintiff argued the statute required personal service of the notification, not via certified mail. Defendant removed the case to federal court on the ground the case depended on an interpretation of a federal tax statute. The district court agreed, denied Plaintiff’s request for a remand, and granted Defendant summary judgment on the merits. The Sixth Circuit affirmed. The U.S. Supreme Court granted certiorari on the jurisdictional question alone to determine if federal question jurisdiction requires the presence of a federal cause of action.
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