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MATTHEWS V. RODGERS, 284 U. S. 521 (1932)

U.S. Supreme Court

Matthews v. Rodgers, 284 U.S. 521 (1932)

Matthews v. Rodgers

No. 84

Argued December 1, 2, 1931

Reargued January 11, 1932

Decided February 15, 1932

284 U.S. 521


1. Objection to the equity jurisdiction of the District Court held to have been properly raised by motion to dismiss the bill, and preserved by assignments of error in this Court. P. 284 U. S. 524.

2. The rule, emphasized by Jud.Code § 267, that suits in equity shall not be maintained in the federal courts in any case where a plain, adequate, and complete remedy may be had at law is of peculiar force in cases in which it is sought to enjoin the collection of state taxes. P. 284 U. S. 525.

3. That refusal to pay an allegedly unconstitutional state tax will result in civil and criminal penalties and irreparable damage to the plaintiff's business is not basis for a suit in the federal court to enjoin collection if the legal remedy of paying under protest and suing the collector to recover is afforded by the state law. P. 284 U. S. 526.

4. Such a legal remedy exists under the statutes and decisions of Mississippi. P. 284 U. S. 527.

5. Such legal remedy, although against the collecting officer, rather than the state or municipality, is to be deemed adequate, where the bill does not allege special circumstances showing inability of the plaintiff to pay the tax, or of the collecting officer to respond to judgment. P. 284 U. S. 528.

Page 284 U. S. 522

6. The equity jurisdiction of the inferior federal courts is that of the English Court of Chancery at the time of the separation of the two countries; it cannot be enlarged by state legislation creating new equitable remedies in the state courts. P. 284 U. S. 529.

7 Therefore, the fact that a state has provided a remedy against illegal state taxes by injunction does not authorize the federal courts to enjoin where the legal remedy is adequate. Id.

8. In general, the jurisdiction of equity to avoid multiplicity of actions at law is restricted to cases where there would otherwise b some necessity for the maintenance of numerous suits between the same parties, involving the same issues of law or fact. It does not extend to cases where there are numerous parties plaintiff and the issues between them and the adverse party are not necessarily identical. Id.

9. Where the alleged unconstitutionality of a state tax depend in the case of each of many taxpayers upon its effect upon his particular business in interstate commerce, a suit by or on behalf of all to enjoin the collector cannot be supported as one to avoid a multiplicity of actions. P. 284 U. S. 530.


Appeal from a decree of the District Court of three judges, which enjoined the county sheriff and ex officio tax collector and three members of the state Board of Tax Commissioners from collecting certain "privilege" taxes. The bill was filed by numerous plaintiffs on behalf of themselves and of all others similarly situated.

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