California v. Grace Brethren Church

In California v. Grace Brethren Church (1982) 457 U.S. 393, state tax laws were challenged as violating the establishment and free exercise clauses of the First Amendment. The Supreme Court held that the Tax Injunction Act (28 U.S.C. 1341) prohibits declaratory relief as well as injunctive relief against the state taxing authorities unless there is no plain, speedy and efficient remedy for the taxpayer in state court. The court stated that "Carving out a special exception for taxpayers raising First Amendment claims would undermine significantly Congress' primary purpose 'to limit drastically federal district court jurisdiction to interfere with so important a local concern as the collection of taxes.' " (457 U.S. at pp. 416-417.) The court indicated that a claimed violation of the equal protection clause ought to be treated no differently. The court rejected the taxpayer's claim that they had no plain, speedy, and efficient remedy because they must meet certain record keeping, registration and reporting requirements before bringing a state court refund suit.