Maraia et al v. City of Cranston, RI

CourtDistrict Court, D. New Hampshire
DecidedMarch 29, 1999
Docket98-CV-173-B
StatusPublished

This text of Maraia et al v. City of Cranston, RI (Maraia et al v. City of Cranston, RI) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Maraia et al v. City of Cranston, RI, (D.N.H. 1999).

Opinion

Maraia et al v. City of Cranston, RI 98-CV-173-B 03/29/99

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Joseph Maraia, et. al

v. N.H. Civil No. S-CV-173-B R . I . Civil N o . S-CV-25 The City of Cranston, et. a l ,

MEMORANDUM AND ORDER

_____ The plaintiffs in this class action pay sewer assessments to

the City of Cranston, Rhode Island. Their complaint against the

city and several of its officials concerns the city's agreement

to lease its sewer system to a private corporation in exchange

for a $48 million loan and other consideration. This lease

agreement obligates the city's sewer fee payers to repay the loan

and compensate the private corporation for operating and

maintaining the sewer system.

Plaintiffs initially filed their complaint in state court.

They allege that the city is violating state law by using some

proceeds of the loan to pay debts unrelated to the operation of

the sewer system. They also claim that the city violated state

and federal law by entering into the lease agreement and

accepting the loan without first holding a city-wide vote. Among

other forms of relief, plaintiffs seek an injunction barring the

City Council from raising sewer assessments to repay the

allegedly illegal loan. Defendants removed the case to federal

- 1 - court relying on the fact that the complaint contains claims

based on federal law. See 28 U.S.C.A. § 1441(b) (West 1994).

Plaintiffs now seek to have the case remanded on the ground that

the Tax Injunction Act ("TIA"), 28 U.S.C.A. § 1341 (West 1994),

deprives the court of subject matter jurisdiction.

II. BACKGROUND

Cranston operates its city-wide sewer system pursuant to a

grant of authority from the Rhode Island General Assembly. See

P.L. 1939, Chapter 750, An Act to Create A Sewer Commission For

the City of Cranston and to Authorize Said City to Construct and

Maintain a Sewer System as amended by Chapter 1372 of the Public

Law, 1943, and by Chapter 1891, P.L. 1947. Approximately 92

percent of the City's residences and virtually all of its public

business and industrial facilities are connected to the system.1

A city ordinance reguires that any residence or business whose

property is located within 100 feet of a sewer line must be

connected to the sewer system. See Cranston City Code, Art. II,

Sec. 26-8.

All cities and towns in Rhode Island are authorized to enact

ordinances imposing sewer assessments. See R.I. Gen. L. § 45-14-

1 A few residences in the city have septic systems and a small section of the city is served by the City of Warwick's sewer system. See PI. Ex. A, Rhode Island Clean Water Finance Agency Preliminary Official Statement of Aug. 22, 1997, at 30. 1. Cranston funds the cost of operating its sewer system though

annual charges that vary depending upon the type of user.

Residential users and buildings containing clubs, libraries and

hospitals are charged a flat fee per unit. The assessment for

business users is based upon the number of employees. The

assessment for restaurants and clubs is based upon seating

capacity and the charge for laundries is based upon the number of

washing units. Public buildings are assessed based on the number

of fixtures located in the building. Industrial users are

assessed a minimum charge based upon the number of employees and

an additional charge based upon the user's sewage flow rate and

the nature of the pollutants contained in its waste stream. Non­

users whose properties abut a sewer line are also charged a flat

fee. See Cranston City Code, Article VI, Sec. 26-71.

On March 7, 1997, Cranston entered into an agreement to

lease its sewer system to Triton Ocean State LLC, a private

corporation. In exchange for the city's agreement to make

monetary payments to Triton during the agreement's 25-year term,

Triton agreed to (1) operate, repair and maintain the sewer

system; (2) finance and make certain capital improvements to the

system; and (3) pay the city $48 million at the commencement of

the contract. The city has agreed to fund its obligations under

the lease agreement with the proceeds of its annual sewer

- 3 - assessments.

II. DISCUSSION

_____ The Tax Injunction Act provides, in pertinent part, that

"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." 28 U.S.C. § 1341. The Court has established that

the policy rationale underlying the TIA bars declaratory,

injunctive, and monetary relief, see National Private Truck

Council, Inc. v. Oklahoma Tax Comm'n, 515 U.S. 582, 586-87

(1995); California v. Grace Brethren Church, 457 U.S. 393, 411

(1982), and that actions which would enjoin the collection of

local taxes are within the reach of the statute. See Collins

Holding Corp. v. Jasper County, South Carolina, 123 F.3d 797, 799

n. 1 (4th Cir. 1997). The TIA is a complete bar to federal

jurisdiction. It is not subject to waiver, and, if applicable,

will require the remand of this case to the Rhode Island state

courts. See Cumberland Farms, Inc. v. Tax Assessor, State of

Maine, 116 F.3d 943, 945 (1st Cir. 1997); Bank of New England Old

Colony, N .A . v. Clark, 986 F.2d 600, 604 (1st Cir. 1993)

(affirming remand of case due to applicability of TIA).

Two conditions must be satisfied for the TIA to deprive a

- 4 - federal court of subject matter jurisdiction: (1) the challenged

claim must seek to "enjoin, suspend or restrain the assessment,

levy, or collection of a tax" and (2) the state courts must

furnish a "plain, speedy, and efficient remedy" for the alleged

violation. 28 U.S.C. § 1341. See also Cumberland Farms, 116

F.3d at 945. I examine the applicability of each condition in

turn.

A. Is the Cranston Sewer Assessment a Tax?
1. Purpose of the Tax Injunction Act

The deference which the TIA reguires federal courts to pay

to state and local governments in their collection of revenue is

premised on the principle of federalism. The Act reflects the

"scrupulous regard for the rightful independence of state

governments . . . and a proper reluctance to interfere by

injunction with their fiscal operations." Hillsborough v.

Cromwell, 326 U.S. 620, 622 (1946); see also Tullv v. Griffin,

429 U.S. 68, 73 (1976) (noting the Act's purpose of recognizing

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Township of Hillsborough v. Cromwell
326 U.S. 620 (Supreme Court, 1946)
Tully v. Griffin, Inc.
429 U.S. 68 (Supreme Court, 1976)
Rosewell v. LaSalle National Bank
450 U.S. 503 (Supreme Court, 1981)
California v. Grace Brethren Church
457 U.S. 393 (Supreme Court, 1982)
Cumberland Farms, Inc. v. Tax Assessor, Maine
116 F.3d 943 (First Circuit, 1997)
Arthur G. Carson Et Ux. v. City of Fort Lauderdale
293 F.2d 337 (Fifth Circuit, 1961)
Arthur L. Tramel v. George Schrader
505 F.2d 1310 (Fifth Circuit, 1975)
Schneider Transport, Inc. v. Cattanach
657 F.2d 128 (Seventh Circuit, 1981)
Burris v. City Of Little Rock
941 F.2d 717 (Eighth Circuit, 1991)
Costello v. Ricci
401 A.2d 38 (Supreme Court of Rhode Island, 1979)
Group Assisting Sewer Proposal-Ansonia v. City of Ansonia
448 F. Supp. 45 (D. Connecticut, 1978)
Kerns v. Dukes
153 F.3d 96 (Third Circuit, 1998)

Cite This Page — Counsel Stack

Bluebook (online)
Maraia et al v. City of Cranston, RI, Counsel Stack Legal Research, https://law.counselstack.com/opinion/maraia-et-al-v-city-of-cranston-ri-nhd-1999.