Franchise Tax Board of California v. Hyatt (short: Hyatt II), 578 U.S. 171 (2016), was a United States Supreme Court case in which the Court held that the Nevada rule that does not extend the same immunities to agencies of other states as it does to its own is effectively a "policy of hostility", which is unconstitutional under the Full Faith and Credit Clause. The Court split equally on the question whether Nevada v. Hall should be overruled, effectively upholding it.[1][2][3][4]
| Franchise Tax Board of California v. Hyatt | |
|---|---|
 | |
| Argued December 7, 2015 Decided April 19, 2016 | |
| Full case name | Franchise Tax Board of California, Petitioner v. Gilbert P. Hyatt |
| Docket no. | 14-1175 |
| Citations | 578 U.S. 171 (more) 136 S. Ct. 1277; 194 L. Ed. 2d 431 |
| Holding | |
| The Nevada rule not extending the same immunities to agencies of other states as it does to its own is a "policy of hostility" and unconstitutional under the Full Faith and Credit Clause. | |
| Court membership | |
| |
| Case opinions | |
| Majority | Breyer, joined by Kennedy, Ginsburg, Sotomayor, Kagan |
| Concurrence | Alito (in judgment) |
| Dissent | Roberts, joined by Thomas |
Background
editThis section needs expansion. You can help by adding missing information. (February 2026) |
United States Supreme Court
editThe Supreme Court issued its opinion on April 19, 2016.[1] Writing for a 6-2 majority, Justice Breyer reasoned that the Supreme Court of Nevada's decision "applied a special rule of law applicable only in lawsuits against its sister States." Such a rule was unconstitutional under the Full Faith and Credit Clause.
Dissenting opinion
editChief Justice Robers wrote a dissenting opinion, joined by Justice Thomas.[1]
Subsequent developments
editIn 2019, in a majority opinion written by Justice Thomas, the Court expressly overruled Nevada v. Hall.[5]
References
edit- 1 2 3 "Franchise Tax Board of California v. Hyatt". Oyez. Retrieved May 15, 2020.
- ↑ "Franchise Tax Bd. of Cal. v. Hyatt, 578 U.S. ___ (2016)". Justia Law. Retrieved May 15, 2020.
- ↑ Gutoff, Jonathan M. (2017). "Franchise Tax Board of California v. Hyatt: A Split Court, Full Faith and Credit, and Federal Common Law". Roger Williams University Law Review. 22: 248.
- ↑ Hananel, Sam (April 20, 2016). "Tie leaves states facing lawsuits in other states". Reno Gazette-Journal.
- ↑ "Franchise Tax Board of California v. Hyatt, 587 U.S. ___ (2019)". Justia Law. Archived from the original on November 15, 2025. Retrieved February 17, 2026.
External links
edit- Text of Franchise Tax Bd. of Cal. v. Hyatt, No. 14-1175, 578 U.S. ___ (2016) is available from: CourtListener Google Scholar Internet Archive (docket files) Justia Oyez (oral argument audio) Supreme Court (slip opinion) (archived)
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