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Stratton v. St. Louis Southwestern Railway Co., 284 U.S. 530 (1932)

Stratton v. St. Louis Southwestern Railway Co.

No. 178

Argued December 2, 3, 1931

Reargued January 11, 1932

Decided February 15, 1932

284 U.S. 530


1. A suit will not lie in a federal court to enjoin a state officer from collecting a tax that violates the Federal Constitution, where the state law affords a legal remedy through payment of the tax under protest and suit to recover it from the collecting officer, and no special circumstance are alleged in the bill which would render the

Page 284 U. S. 531

legal remedy inadequate. Cf. Matthews v. Rodgers, ante, p. 284 U. S. 521. Pp. 284 U. S. 532-534.

2. Such a legal remedy is afforded by the law of Illinois where the tax payment is under duress, as where made to avoid forfeiture of a corporate franchise. P. 284 U. S. 532.

3. A state law providing a new equitable remedy cannot increase or diminish the equity jurisdiction of federal courts. P. 284 U. S. 533.

4. In determining what is a legal remedy and its adequacy to defeat their equity jurisdiction, the federal courts are guided by the historic distinction between law and equity in those courts, not by the name given to remedies or to distinctions made between them by state practice. P. 284 U. S. 534.

5. A remedy by action to recover a tax which has been paid is essentially a legal remedy, and not the less so because the state practice has annexed to it a remedy by injunction for staying payment over of the tax money, so that it may be available to satisfy judgment against the collector. Id.


Appeal from a decree of the District Court of three judges enjoining assessment and collection of a corporation franchise tax.

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