EAST, District Judge.
This three-judge Court was constituted by order of the Chief Circuit Judge of the Court of Appeals for the Ninth Circuit,1 and the cause first came on for hearing upon the several motions of the defendants and the intervenor defendants for an order dismissing plaintiffs’ complaint and cause.2 The defendants and the intervenors renewed their respective motions to dismiss plaintiffs’ amended complaint and action. Counsel have ably briefed and presented to the Court the questions involved.
Parties
The plaintiffs, “North Bonneville Committee,” are voluntary assignees of al-[399]*399Ieged claims held by some 47 Federal employees working at the Bonneville Dam Project, all under the supervision of the Corps of the United States Engineers. The Bonneville Dam is a reclamation and hydroelectric project on the Columbia River some 40 miles upstream from the Portland, Oregon-Vancouver, Washington vicinity, and the Dam extends from the shores of the State of Washington to the shores of the State of Oregon.
The defendants, as the caption designates, aside from defendant United States of America, are supervisory personnel of these 47 Federal employees, and the intervenors are the duly appointed, qualified and acting Commissioners of the State Tax Commission of the State of Oregon.
Plaintiffs’ First Cause of Action
The plaintiffs show that part of the duties of 22 of their 47 employee-assignors are performed within the State of Washington, and part are performed within the State of Oregon in connection with their employment on the Dam Project. The percentage of income earned by these 22 employees within the State of Oregon is varied from a high of 90% to a low of 50% of their respective total wages paid by the United States Government.
The plaintiffs further show that the defendants, pursuant to the President’s Executive Order, implemented and authorized by an Act of Congress,3 in line with the laws and regulations of the State of Oregon, have been and are deducting and withholding from the mentioned 22 employees’ total wages an amount equal to the withholding tax deductions from the wages of Oregon residents with a like total wage, all without reference as to what amount of the wages of the mentioned 22 employees respectively was earned within the State of Washington.
As appears from the statements of counsel in open Court, when these 22 employees file their respective income tax returns with the State of Oregon showing the true amount of wages earned within the State of Oregon and their allowable deductions arising within the State of Oregon, they then receive the benefit of the amount of the withholding from their respective wages as credit upon their income tax due the State of Oregon, or if overpaid, have a claim for a refund. The plaintiffs and their 22 as[400]*400signors involved are aggrieved by reason of the fact that defendants deduct and withhold the ■ required withholding amount from the wages of the employees earned outside the State of Oregon, and then in turn have to await throughout the entire taxable period to obtain administrative refund of the amounts withheld from their wages actually earned within the State of Washington. Therefore, the plaintiffs claim that their assignors’ property is being taken by the defendants and the intervenors without due process of law in violation of 5 U.S.C.A. §§ 84a and 84b and contrary to the Oregon statutes and specific published rules and regulations of the tax authorities of the State of Oregon.4
However, the intervenors disclaim the application of this statutory and regulatory law and contend that the law of the matter is governed by other statutes and regulations.5
Furthermore, the plaintiffs, on behalf of their respective 22 assignors, claim that the actions of the defendants are without authority in law and violate their and their assignors’ rights, as set forth in par. 1, § 2, Article IV of the Constitution of the United States, providing :
“[1] The Citizens of each State shall be entitled to all privileges and immunities of Citizens in the- several States.”
and also as set forth in Amendment V of said Constitution, providing in part:
“No person shall * * * be deprived of life, liberty, or * * due process of law.”
and also as set forth in Amendment XIV, § 1 of said Constitution, providing in part:
“ * * * nor shall any State deprive any person of life, liberty, or property, without due process of law;” ■
and also in violátion of the commerce clause of the Constitution set forth in § 1, Article VIII (sic).
The plaintiffs further allege that they have no other plain, speedy, or efficient remedy in the matter and ask that the defendants and the intervenors be permanently enjoined from withholding any moneys for Oregon taxes from the salaries of the 22 persons named in the first cause of action. And in connection with the plaintiffs’ second cause of action they ask that the defendants and the interven-ors be permanently enjoined from withholding any moneys whatsoever for income taxes for the State of Oregon -from the salaries of the 47 assignors of plaintiffs referred to.
Plaintiffs’ Second Cause of Action
In plaintiffs’ second cause of action they reassert and claim for all of their 47 assignors that the defendants’ action in withholding for the benefit of the State of Oregon amounts computed to their entire wages, as above set forth, violates their respective Constitutional rights in all respects set forth in their first cause of action.
The plaintiffs further claim that, pursuant to the Oregon statutes, as implemented and put into effect by the action of the defendants in their withholding of amounts from their respective net income as nonresidents- of the State of Oregon, they are subjected to an income tax upon a basis which favors the residents of Oregon and disfavors these residents of Washington. It would appear that the statutes of the State of Oregon permit an Oregon resident to claim a statutory deduction without explanation, based upon percentages of income from their taxable income, which deductions are not permitted to residents of other states, and particularly plaintiffs’ assignors.6
[401]*401In addition to the alleged violation the Constitutional rights claimed by plaintiffs on behalf of their 22 assignors as set forth in the first cause of action, the plaintiffs, in their second cause' of action on behalf of their 47 assignors, reallege' that each of their assignors’ Constitutional rights with respect to Amendments IV, V and XIV are being violated by the alleged action of defendants and intervenors.
It would appear to this Court that this claimed “denial of equal protection of the laws” would constitute the mainstay of the plaintiffs and their assignors.
$3,000.00 Amount Jurisdictional Limitation of this Court
The defendants and the intervenors urge that this Court is without jurisdiction to hear the causes of plaintiffs because the amount of jurisdictional limitation has not been shown.
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EAST, District Judge.
This three-judge Court was constituted by order of the Chief Circuit Judge of the Court of Appeals for the Ninth Circuit,1 and the cause first came on for hearing upon the several motions of the defendants and the intervenor defendants for an order dismissing plaintiffs’ complaint and cause.2 The defendants and the intervenors renewed their respective motions to dismiss plaintiffs’ amended complaint and action. Counsel have ably briefed and presented to the Court the questions involved.
Parties
The plaintiffs, “North Bonneville Committee,” are voluntary assignees of al-[399]*399Ieged claims held by some 47 Federal employees working at the Bonneville Dam Project, all under the supervision of the Corps of the United States Engineers. The Bonneville Dam is a reclamation and hydroelectric project on the Columbia River some 40 miles upstream from the Portland, Oregon-Vancouver, Washington vicinity, and the Dam extends from the shores of the State of Washington to the shores of the State of Oregon.
The defendants, as the caption designates, aside from defendant United States of America, are supervisory personnel of these 47 Federal employees, and the intervenors are the duly appointed, qualified and acting Commissioners of the State Tax Commission of the State of Oregon.
Plaintiffs’ First Cause of Action
The plaintiffs show that part of the duties of 22 of their 47 employee-assignors are performed within the State of Washington, and part are performed within the State of Oregon in connection with their employment on the Dam Project. The percentage of income earned by these 22 employees within the State of Oregon is varied from a high of 90% to a low of 50% of their respective total wages paid by the United States Government.
The plaintiffs further show that the defendants, pursuant to the President’s Executive Order, implemented and authorized by an Act of Congress,3 in line with the laws and regulations of the State of Oregon, have been and are deducting and withholding from the mentioned 22 employees’ total wages an amount equal to the withholding tax deductions from the wages of Oregon residents with a like total wage, all without reference as to what amount of the wages of the mentioned 22 employees respectively was earned within the State of Washington.
As appears from the statements of counsel in open Court, when these 22 employees file their respective income tax returns with the State of Oregon showing the true amount of wages earned within the State of Oregon and their allowable deductions arising within the State of Oregon, they then receive the benefit of the amount of the withholding from their respective wages as credit upon their income tax due the State of Oregon, or if overpaid, have a claim for a refund. The plaintiffs and their 22 as[400]*400signors involved are aggrieved by reason of the fact that defendants deduct and withhold the ■ required withholding amount from the wages of the employees earned outside the State of Oregon, and then in turn have to await throughout the entire taxable period to obtain administrative refund of the amounts withheld from their wages actually earned within the State of Washington. Therefore, the plaintiffs claim that their assignors’ property is being taken by the defendants and the intervenors without due process of law in violation of 5 U.S.C.A. §§ 84a and 84b and contrary to the Oregon statutes and specific published rules and regulations of the tax authorities of the State of Oregon.4
However, the intervenors disclaim the application of this statutory and regulatory law and contend that the law of the matter is governed by other statutes and regulations.5
Furthermore, the plaintiffs, on behalf of their respective 22 assignors, claim that the actions of the defendants are without authority in law and violate their and their assignors’ rights, as set forth in par. 1, § 2, Article IV of the Constitution of the United States, providing :
“[1] The Citizens of each State shall be entitled to all privileges and immunities of Citizens in the- several States.”
and also as set forth in Amendment V of said Constitution, providing in part:
“No person shall * * * be deprived of life, liberty, or * * due process of law.”
and also as set forth in Amendment XIV, § 1 of said Constitution, providing in part:
“ * * * nor shall any State deprive any person of life, liberty, or property, without due process of law;” ■
and also in violátion of the commerce clause of the Constitution set forth in § 1, Article VIII (sic).
The plaintiffs further allege that they have no other plain, speedy, or efficient remedy in the matter and ask that the defendants and the intervenors be permanently enjoined from withholding any moneys for Oregon taxes from the salaries of the 22 persons named in the first cause of action. And in connection with the plaintiffs’ second cause of action they ask that the defendants and the interven-ors be permanently enjoined from withholding any moneys whatsoever for income taxes for the State of Oregon -from the salaries of the 47 assignors of plaintiffs referred to.
Plaintiffs’ Second Cause of Action
In plaintiffs’ second cause of action they reassert and claim for all of their 47 assignors that the defendants’ action in withholding for the benefit of the State of Oregon amounts computed to their entire wages, as above set forth, violates their respective Constitutional rights in all respects set forth in their first cause of action.
The plaintiffs further claim that, pursuant to the Oregon statutes, as implemented and put into effect by the action of the defendants in their withholding of amounts from their respective net income as nonresidents- of the State of Oregon, they are subjected to an income tax upon a basis which favors the residents of Oregon and disfavors these residents of Washington. It would appear that the statutes of the State of Oregon permit an Oregon resident to claim a statutory deduction without explanation, based upon percentages of income from their taxable income, which deductions are not permitted to residents of other states, and particularly plaintiffs’ assignors.6
[401]*401In addition to the alleged violation the Constitutional rights claimed by plaintiffs on behalf of their 22 assignors as set forth in the first cause of action, the plaintiffs, in their second cause' of action on behalf of their 47 assignors, reallege' that each of their assignors’ Constitutional rights with respect to Amendments IV, V and XIV are being violated by the alleged action of defendants and intervenors.
It would appear to this Court that this claimed “denial of equal protection of the laws” would constitute the mainstay of the plaintiffs and their assignors.
$3,000.00 Amount Jurisdictional Limitation of this Court
The defendants and the intervenors urge that this Court is without jurisdiction to hear the causes of plaintiffs because the amount of jurisdictional limitation has not been shown. As to plaintiffs’ first cause of action, this Court would take the view that in tax matters of this nature the amount jurisdictional limitation should be determined on the annual basis rather than an accumulative basis, and upon an individual rather than an aggregate basis. Healy v. Ratta, 292 U.S. 263, at page 271, 54 S.Ct. 700, 78 L.Ed. 1248. As none of the plaintiffs’ assignors’ individual claims for any one year involved meets the amount limitation of this Court’s jurisdiction, it would appear that plaintiffs’ first cause of action could be, on that ground, dismissed.
This conclusion must not be deemed as any adjudication as to whether or not the amount jurisdictional limitation of this Court is involved in connection with plaintiffs’ second cause of action.
This Court’s Jurisdiction to Interfere with State Official Action
.At the threshold of this query it is necessary to determine whether or not the defendants, in colleague with the intervenors by reason of an Act of Congress and the President’s Proclamation, are acting pursuant to a law of the State of Oregon or an Act of Congress. It is the view of this Court that the defendants, in the course of their withholding of sums for the use and benefit of the State of Oregon from the wages payable to the plaintiffs and their respective assignors, were acting under Federal authority to assist and enforce the laws and regulations of officials of the State of Oregon. The net result must be that by leave of Congress the defendants are putting into effect the office of the State of Oregon’s laws, statutes and regulations rather than the Acts of Congress. Therefore, this Court must deal with Title 28 U.S.C.A. § 1341, which reads as follows:
“The district courts shall not enjoin, suspend or restrain the assessment, levy or collection of any tax under State law where a plain, speedy and efficient remedy may be had in the courts of such State.”
This Court is bound to take judicial knowledge of the statutes and administrative acts of the State of Oregon. Without detail, those statutes and laws provide for an opportunity for these plaintiffs and their respective assignors to be heard by the State Tax Commission, administratively, and by the Courts of the State of Oregon, judicially, as to their grievances.7
[402]*402Next, we are obliged to consider the purpose and effect of Title 28 U.S.C.A. § 1343, which provides, inter alia:
“The district courts shall have original jurisdiction of any civil action authorized by law to be commenced by any person: * * *
“3. To redress the deprivation, under color of any State law, statute, ordinance, regulation, custom or usage, of any right, privilege or immunity secured by the Constitution of the United States or by any Act of Congress providing for equal rights of citizens or of all persons within the jurisdiction of the United States. June 25, 1948, c. 646, 62 Stat. 932.”
We have already determined that it is our view that the defendants, while Federal officials, are acting as agents of the State of Oregon and enforcing the laws of the State of Oregon, and it has already been determined that the plaintiffs and their respective assignors have administrative and judicial procedures open to them to air their grievances against the action of the officials and the laws of the State of Oregon.
We are convinced that the rights obtaining under Title 28 U.S.C.A. § 1343, whether they be personal or monetary rights, are still subject to the restrictions placed upon the jurisdiction of this Court under Title 28 U.S.C.A. § 1341. It follows that this Court has no office to hear the complaints of plaintiffs until after an administrative determination by the intervenor defendants and a review by the judiciary of the Staté of Oregon of plaintiffs’ present complaints have been had, and only then if there be left a complaint that the State of Oregon did not provide:
“A plain, speedy and efficient remedy, .which may 'be had in the Courts of such State.”
Any such complaint of plaintiffs may then be heard. Shipman v. DuPre, 1950, 339 U.S. 321, 70 S.Ct. 640, 94 L.Ed. 877. Therefore, the amended complaint of the plaintiffs and their two causes of action should be dismissed.
Having disposed of the contentions of the plaintiffs on the foregoing grounds, it is unnecessary for this Court to consider the other grounds for Constitutional relief claimed by the plaintiffs.
Counsel for defendants and intervenor defendants should submit appropriate orders of dismissal.