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Robert C. Steiner, et ux. v. Utah State Tax Commission

Paid petition · Supreme Court of Utah, No. 20180223 · judgment August 14, 2019


Certiorari denied · February 24, 2020
Pre-decision estimate: 2% cert probability

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

Question presented

Utah’s tax code extends a credit for income taxes paid to other States but does not extend a similar credit for income taxes paid to foreign countries or make other adjustments for foreign income. The result is a double taxation of income that state residents earn from foreign commerce. The question presented is whether this scheme discriminates against foreign commerce in violation of the dormant Commerce Clause. (i)

Counsel of record

For petitioner
Neal Kumar Katyal
Milbank LLP

For respondent
Tyler Green
Consovoy McCarthy PLLC

Case

Conference history
Distributed for 1 conference

Amicus briefs
3 cert-stage

Linked docket
19A426

Proceedings

  1. Feb 24 2020
    Petition DENIED.
  2. Jan 22 2020
    DISTRIBUTED for Conference of 2/21/2020.
  3. Jan 13 2020
    Brief amicus curiae of American Legislative Exchange Council filed.
  4. Jan 13 2020
    Brief amicus curiae of Council On State Taxation filed.
  5. Jan 13 2020
    Waiver of right of respondent Utah State Tax Commission to respond filed.
  6. Jan 13 2020
    Brief amici curiae of Professors Michael S. Knoll and Donald T. Williamson, and the Kogod Tax Policy Center filed.
  7. Dec 12 2019
    Petition for a writ of certiorari filed. (Response due January 13, 2020)
  8. Oct 18 2019
    Application (19A426) granted by Justice Sotomayor extending the time to file until December 12, 2019.
  9. Oct 17 2019
    Application (19A426) to extend the time to file a petition for a writ of certiorari from November 12, 2019 to December 12, 2019, submitted to Justice Sotomayor.