Supreme Court Report

Supreme Court of the United States · Official docket →

Ryan K. Jones, et ux. v. United States

Paid petition · United States Court of Appeals for the Tenth Circuit, No. 23-5112 · judgment June 10, 2024


Certiorari denied · October 21, 2024
Pre-decision estimate: 6% cert probability (95% interval 4%–10%)

Before the decision, about 1.6× the 4.1% base rate. The model weighted this up for a circuit split argued in the petition, a dissent in the court below (flagged in the petition), and a petition filed soon after the judgment below.

Question presented

The Internal Revenue Code of 1986, as amended ("IRC") grants the Internal Revenue Service ("IRS") collection powers for the income, and other, taxes vastly in excess of powers available to ordinary creditors. The IRS has been so empowered by two different sources of law, both of which arise exclusively from this Court’s rulings: (1) beginning with United States v. Thompson, 98 U.S. 486 (1878), this Court has been ruling that the IRS succeeded to the absolute, functionally-unlimited powers to collect taxes of the King of England, powers precluding all defenses otherwise available to debtors against creditors AND (2) federal courts have been applying this Court’s jurisprudence arising out of its interpretation – as shown in United States v. Carolene Products, 304 U.S. 144 (1938), Wickard v. Filburn, 317 U.S. 111 (1942) etc. – of the Interstate Commerce clause of the Constitution’s Article I § 8 as authority granting the IRS discretionary power over all questions in administering the tax laws against citizens if it claims to have any purported "rational basis" for any of its decisions. The questions presented are: 1. Whether this Court should overrule United States v. Thompson, and all of the cases which followed it, which relied on its declaration of inherent (unstated in the Constitution), absolute, functionallyunlimited sovereign tax-collection power in the central, federal government vis-à-vis U.S. citizens,

Counsel of record

For petitioner
Clifford N. Ribner
Suite 1130

For respondent
Elizabeth B. Prelogar
Solicitor General

Case

Conference history
Distributed for 1 conference

Proceedings

  1. Oct 21 2024
    Petition DENIED.
  2. Oct 02 2024
    DISTRIBUTED for Conference of 10/18/2024.
  3. Sep 30 2024
    Waiver of right of respondent United States of America to respond filed.
  4. Sep 09 2024
    Petition for a writ of certiorari filed. (Response due October 11, 2024)