Dawson v. Steager

139 S. Ct. 698 (2019)

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Nature of the Case

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Facts

P worked in the U. S. Marshals Service. After he retired, he began looking into the tax treatment of his pension. West Virginia, doesn’t tax the pension benefits of certain former state law enforcement employees. But it does tax the benefits of all former federal employees. P brought this suit alleging that West Virginia violated 4 U. S. C. §111. In that statute, the United States has consented to state taxation of the “pay or compensation” of “officers or employees of the United States,” but only if the “taxation does not discriminate against the officer or employee because of the source of the pay or compensation.” §111(a). A West Virginia trial court found it “undisputed” that “there are no significant differences between P’s powers and duties as a US Marshal and the powers and duties of the state and local law enforcement officers” that West Virginia exempts from income tax. P got the verdict. But the West Virginia Supreme Court of Appeals reversed; the statute’s “intent . . . was to give a benefit to a narrow class of state retirees,” not to harm federal retirees. P appealed.