Massachusetts v. United States

435 U.S. 444 (1978)

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Nature of the Case

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Facts

Congress imposed an annual registration tax on all civil aircraft that fly in the navigable airspace of the United States. The tax was part of a comprehensive program to recoup the costs of federal aviation programs from those who use the national air system. The Federal Government has expended significant amounts of federal funds to develop and strengthen an integrated national air system and to make civil air transportation safe and practical. It has established, developed, and improved a wide array of air navigational facilities and services that benefit all aircraft flying in the Nation's navigable airspace, and it has also made substantial grants to state and local governments to assist in planning and developing airports. The financing measures in the Revenue Act are intended to promote two purposes. First, they are designed to serve the congressional policy of having those who especially benefit from Government activity help bear the cost. P challenged the annual aircraft registration tax. That tax imposed an annual 'flat fee' tax on all civil aircraft, including those owned by State and National Governments, that fly in the navigable airspace of the United States. The registration tax was expected to produce only modest revenues and was understood to be only indirectly related to system use. Congress regarded it as an integral and essential part of the network of user charges. P owns several aircraft that are subject to the tax. D notified P that it had been assessed for a tax of $131.43 on this state police helicopter for the period from July 1, 1970, to June 30, 1971. P refused to pay and D thereafter levied on one of P's bank accounts and collected this tax, plus interest and penalties. P sued for a refund of the money collected. P claimed that D may not constitutionally impose a tax that directly affects the essential and traditional state function of operating a police force. The District Court dismissed the complaint. The court held in part that the tax in question is a user fee and that, whatever the present scope of the constitutional principle of implied immunity of a state government from federal taxes, a user fee does not implicate the doctrine. The Court of Appeals affirmed.