United States v. Boyd (1963)
- Docket
- 185
- Decided
- 1963-01-01
- Category
- General
Summary
Question: Does the imposition of the contractor’s tax violate the federal immunity from state taxation? Conclusion: No. Justice Byron R. White delivered the unanimous opinion. The Court held that the Constitution creates immunity from state taxes for the federal government and its properties, but that protection does not extend to federal contractors. Although a contractor may provide goods only to the federal government, the company still enters into a contract that results in financial compensation. Therefore, the contractor always stands to benefit financially and should not be immune from taxation. In this case, the Atomic Energy Commission chose to contract to separate companies rather than hire its own employees, so it may not confer tax immunities onto those contractors. In his concurring opinion, Justice John M. Harlan wrote that this case might have been a good opportunity to reconsider the issue of federal immunity from state taxes. However, given the legislative history surrounding this case, he concurred in the judgment of the court.