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Ashland Specialty Co., Inc. v. Dale W. Steager, West Virginia State Tax Commissioner

Paid petition · Supreme Court of Appeals of West Virginia, No. 17-0437 · judgment May 1, 2018


Certiorari denied · June 17, 2019
Pre-decision estimate: 1% cert probability

Before the decision, well below the 4.1% base rate, with no standout signals pointing toward a grant.

Question presented

A State punished a small business’s inadvertent civil noncompliance by automatically applying a civil monetary penalty at the maximum percentage rate – 500% – without exercising discretion or considering any mitigating circumstances. Was the penalty grossly disproportionate to the offense and unconstitutional under the Eighth Amendment’s Excessive Fines Clause and United States v. Bajakajian? In light of the myriad criteria currently employed by state and federal courts to evaluate gross disproportionality, should the Court resolve the multiple splits and affirmatively adopt factors, like those in Cooper Industries v. Leatherman, to decide whether a civil monetary penalty is grossly disproportionate to the underlying offense?

Counsel of record

For petitioner
Mark Allen Loyd
Dentons Bingham Greenebaum LLP

For respondent
Lindsay Sara See
Office of the West Virginia Attorney General

Case

Conference history
Distributed for 2 conferences

Amicus briefs
2 cert-stage

Linked docket
18A645

Proceedings

  1. Jun 17 2019
    Petition DENIED.
  2. May 28 2019
    DISTRIBUTED for Conference of 6/13/2019.
  3. May 28 2019
    Proof of Service filed with respect to reply brief of petitioner Ashland Specialty Co., Inc.
  4. May 24 2019
    Reply of petitioner Ashland Specialty Co. Inc. filed.
  5. May 15 2019
    Brief of respondent Dale Steager, State Tax Commissioner of West Virginia in opposition filed.
  6. Mar 25 2019
    Motion to extend the time to file a response is granted and the time is extended to and including May 15, 2019.
  7. Mar 21 2019
    Motion to extend the time to file a response from April 15, 2019 to May 15, 2019, submitted to The Clerk.
  8. Mar 18 2019
    Certificate of service with respect to brief amicus curiae of The Bluegrass Institution filed.
  9. Mar 15 2019
    Response Requested. (Due April 15, 2019)
  10. Mar 14 2019
    Supplemental brief of petitioner Ashland Specialty Co. Inc. filed.
  11. Mar 13 2019
    Brief amicus curiae of The Bluegrass Institution filed.
  12. Mar 06 2019
    DISTRIBUTED for Conference of 3/22/2019.
  13. Feb 25 2019
    Blanket Consent filed by Petitioner, Ashland Specialty Co. Inc.
  14. Feb 21 2019
    Waiver of right of respondent Dale Steager to respond filed.
  15. Feb 06 2019
    Petition for a writ of certiorari filed. (Response due March 13, 2019)
  16. Dec 19 2018
    Application (18A645) granted by The Chief Justice extending the time to file until February 6, 2019.
  17. Dec 14 2018
    Application (18A645) to extend the time to file a petition for a writ of certiorari from January 7, 2019 to February 6, 2019, submitted to The Chief Justice.