Query v. United States

Background

The United States and two Army officers sued members of the South Carolina Tax Commission to stop a state license tax on sales at Army post exchanges, officers’ clubs, and similar stores. The complaint said post exchanges are instrumentalities of the U.S. government and that applying the state tax would interfere with federal activities and violate the Constitution. The lower District Court issued an injunction, but the judges and the Court of Appeals disagreed about whether a single district judge or a three-judge panel was required.

Reasoning

The central question was whether the case needed the special three-judge court setup because the plaintiffs attacked the state statute as unconstitutional when applied to federal activities. The Court explained that when a suit asks for an injunction against a state law on constitutional grounds, the statutory rule requiring a three-judge panel applies. Because the complaint and the relief granted rested on a constitutional claim, the case should have been handled by a three-judge court and appealed directly to this Court. The Court therefore vacated the judgment below and sent the case back to the District Court so a proper three-judge decree can be entered and a timely direct appeal to the Supreme Court preserved.

Real world impact

The decision affects disputes where federal activities, like Army post exchanges, claim a state law is unconstitutional. It enforces the procedure for multi-judge review and preserves the route for direct Supreme Court review in those situations, restarting the case under the correct court setup.