Reply in Support of Petition for Writ — State of Ohio v. Janet Yellen (No. 22-880, Supreme Court of the United States)
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A reply in support of a petition for writ of certiorari filed by petitioner State of Ohio in Ohio v. Yellen, No. 22-880, in the Supreme Court of the United States, on petition to the United States Court of Appeals for the Sixth Circuit, dated May 2023. Its Questions Presented ask whether courts have jurisdiction over the States' constitutional challenges to the Tax Mandate and whether the Tax Mandate is unconstitutional. The table of contents lists arguments that the Court should grant certiorari to resolve the acknowledged split, that the Court should decide whether the Tax Mandate is unconstitutional, and that at minimum the Court should hold this case pending resolution of the Secretary's forthcoming petitions. The conclusion asks the Court to grant the petition and reverse.
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Cite this document
“Reply in Support of Petition for Writ — State of Ohio v. Janet Yellen (No. 22-880, Supreme Court of the United States).”
Original at www.supremecourt.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/reply-of-petitioner-ohio-ohio-v-yellen-no-22-880-u-s-may-22-2023-529286f2eb/
, SHA-256 aacf93d89591511dea4e7254bdda2ae5a5fd119133a9011f53c3984d69631e32.Full text
No. 22-880
In the Supreme Court of the United States
______________________________
STATE OF OHIO,
Petitioner,
v.
JANET YELLEN, IN HER OFFICIAL CAPACITY AS
SECRETARY OF THE TREASURY, RICHARD K. DELMAR, IN
HIS OFFICIAL CAPACITY AS ACTING INSPECTOR GENERAL
OF THE DEPARTMENT OF THE TREASURY, AND THE U.S.
DEPARTMENT OF THE TREASURY,
Respondents.
______________________________
ON PETITION FOR WRIT OF CERTIORARI TO THE
UNITED STATES COURT OF APPEALS
FOR THE SIXTH CIRCUIT
______________________________
REPLY IN SUPPORT OF PETITION FOR WRIT
OF CERTIORARI
______________________________
DAVE YOST
Ohio Attorney General
BENJAMIN M. FLOWERS*
*Counsel of Record
Ohio Solicitor General
ZACHERY P. KELLER
MATHURA J. SRIDHARAN
Deputy Solicitors General
30 E. Broad St., 17th Floor
Columbus, Ohio 43215
614-466-8980
bflowers@ohioago.gov
Counsel for Petitioner
i
QUESTIONS PRESENTED
The COVID-19 pandemic devastated the American
economy. In response, Congress passed the American
Rescue Plan Act of 2021, which offered $195 billion in
aid to the States. Pub. L. No. 117-2, 135 Stat. 4. The
States had no choice but to accept; refusing the money
would have given other States and their citizens a sig-
nificant competitive edge in emerging from the pan-
demic. Ohio accepted around $5.4 billion. But accept-
ing the money meant agreeing to the Rescue Plan’s
“Tax Mandate,” which bars States from using Rescue
Plan funds to “directly or indirectly offset a reduction
in … net tax revenue … resulting from a change in
law, regulation, or administrative interpretation.” 42
U.S.C. §802(c)(2)(A).
This case presents two questions, the first of which
has divided the circuits and the second of which is of
immense importance to the States and the Treasury.
1. Do courts have jurisdiction over the States’ con-
stitutional challenges to the Tax Mandate?
2. Is the Tax Mandate unconstitutional?
ii
TABLE OF CONTENTS
Page
QUESTIONS PRESENTED ........................................ i
TABLE OF CONTENTS .............................................ii
TABLE OF AUTHORITIES ..................................... iii
REPLY ......................................................................... 1
I. The Court should grant certiorari to
resolve the acknowledged split. .................... 3
A. The circuits are split regarding the
Final Rule’s effect on Article III
jurisdiction................................................ 3
B. The Secretary concedes the split. ............ 5
II. The Court should decide whether the Tax
Mandate is unconstitutional. ...................... 11
III. At minimum, the Court should hold this
case pending resolution of the Secretary’s
forthcoming petitions. ................................. 12
CONCLUSION.......................................................... 12
iii
TABLE OF AUTHORITIES
Cases Page(s)
Arizona v. Yellen,
34 F.4th 841 (9th Cir. 2022) .............................. 1, 4
Friends of the Earth, Inc. v. Laidlaw
Envtl. Serv.,
528 U.S. 167 (2000) ............................................... 6
Helix Energy Sols. Grp., Inc. v. Hewitt,
598 U.S. 39 (2023) ............................................... 10
Kentucky v. Yellen,
__ F.4th __, 2023 WL 3221058 (6th
Cir. 2023) ....................................................... 2, 6, 9
Kentucky v. Yellen,
54 F.4th 325 (6th Cir. 2022) .................. 1, 2, 4, 5, 9
Missouri v. Yellen,
143 S. Ct. 734 (2023) ............................................. 7
Missouri v. Yellen,
39 F.4th 1063 (8th Cir. 2022) ........................ 2, 5, 7
South Dakota v. Dole,
483 U.S. 203 (1987) ......................................... 1, 10
Susan B. Anthony List v. Driehaus,
573 U.S. 149 (2014) ........................................... 3, 8
United States v. Students Challenging
Regulatory Agency Procedures
412 U.S. 669 (1973) ............................................. 10
iv
West Virginia v. Treasury,
571 F. Supp. 3d 1229 (N.D. Ala.
2021)....................................................................... 9
West Virginia v. Treasury,
59 F.4th 1124 (11th Cir. 2023) .........1, 3, 4, 7, 9, 10
Zivotofsky v. Clinton,
566 U.S. 189 (2012) ............................................. 11
Statutes and Rules
42 U.S.C. §802 ............................................................. 1
31 C.F.R. §35.4 ............................................................ 9
86 Fed. Reg. 26786-01 (May 17, 2021) ................... 4, 9
S. Ct. R. 10 .................................................................. 6
Other Authorities
Petn. for En Banc Review, West Virginia
v. Treasury, No. 22-10168, Doc.104-1
(Mar. 6, 2023)......................................................... 7
Philip Hamburger, Purchasing
Submission: Conditions, Power, and
Freedom (2021) ...................................................... 8
REPLY
The Spending Clause permits Congress to place
conditions on the States’ receipt of federal money. But
Congress may impose conditions only through unam-
biguous terms in non-coercive offers. See South Da-
kota v. Dole, 483 U.S. 203, 207–08, 211 (1987).
These principles doom the Tax Mandate—a condi-
tion hidden away within the American Rescue Plan
Act. The Mandate forbids States from using Rescue
Plan funds to “directly or indirectly offset” any “reduc-
tion in [their] net tax revenue” caused by a tax cut. 42
U.S.C. §802(c)(2)(A) (emphasis added). That language
is vacuous; given the fungibility of money, there is no
way of ascertaining whether Rescue Plan funds were
used to “indirectly offset” lost tax revenue. See West
Virginia v. Treasury, 59 F.4th 1124, 1143–46 (11th
Cir. 2023); Pet.App.54a–63a. Yet each State was com-
pelled to accept these vacuous terms; States had to
agree to the Mandate to obtain the billions of dollars
available through the Rescue Plan, and any State that
rejected that money would have put itself and its citi-
zens at an immense competitive disadvantage in re-
covering economically. Because the Tax Mandate is
an ambiguous term attached to a coercive offer, it is
unconstitutional twice over.
Both circuits to have reached the merits have held
the Mandate unconstitutional on the ground that it
denies the States the clear terms to which they are
constitutionally entitled. See West Virginia, 59 F.4th
at 1140–48; Kentucky v. Yellen, 54 F.4th 325, 346–47
(6th Cir. 2022). But the circuits are split regarding
whether and when the States may challenge the Man-
date. Compare West Virginia, 59 F.4th at 1135–38
and Arizona v. Yellen, 34 F.4th 841, 853 (9th Cir.
2
2022), with Kentucky, 54 F.4th at 335–46 and Pet.
App19a–24a, with Missouri v. Yellen, 39 F.4th 1063,
1067–70 (8th Cir. 2022).
The Secretary (which is how this brief will refer to
the defendants collectively) concedes that the jurisdic-
tional issue is the subject of a circuit split. See BIO.
14–15. And her actions confirm that she considers the
merits question whether the Mandate is constitu-
tional to be important: in both cases where a circuit
has held the Tax Mandate unconstitutional, the Sec-
retary has petitioned for en banc review. See id. The
Sixth Circuit denied en banc review already. Ken-
tucky v. Yellen, __ F.4th __, 2023 WL 3221058 (6th Cir.
2023) (order denying rehearing en banc). The Elev-
enth Circuit will likely follow suit. So it is a matter of
time before the Secretary petitions this Court to de-
cide the jurisdictional and merits questions presented
by Ohio’s case. Indeed, the Secretary’s Brief in Oppo-
sition silently concedes the point by failing to deny it.
And while the Secretary would prefer that the Court
await one of her petitions before agreeing to resolve
these questions, waiting will harm the States further.
Because they must expend their Rescue Plan funds by
2025, delaying review will leave States with little time
to make tax policy free from the “pall” cast by the Tax
Mandate. Pet.App.43a.
The Court should grant Ohio’s petition. At mini-
mum, it should hold this case and consider it alongside
the Secretary’s forthcoming certiorari petitions in
cases presenting the same issues.
3
I. The Court should grant certiorari to resolve
the acknowledged split.
The question of whether and when States may
bring challenges to the Tax Mandate divides the cir-
cuits.
A. The circuits are split regarding the
Final Rule’s effect on Article III
jurisdiction.
1. The Tax Mandate injures Ohio in three ways.
Pet.13.
First, the Tax Mandate inflicts an “imminent re-
coupment” injury. Because the Mandate arguably for-
bids States that cut taxes from spending Rescue Plan
funds, and because Ohio cut taxes, Ohio is subject to
a potential recoupment action by the Secretary. See
Susan B. Anthony List v. Driehaus, 573 U.S. 149, 161–
64 (2014).
Second, the Mandate inflicts “sovereign-authority”
injuries. By denying Ohio the unambiguous and
noncoercive terms to which States are constitutionally
entitled in Spending Clause legislation, the Mandate
interfered with Ohio’s sovereignty before Ohio ac-
cepted Rescue Plan funds. Post-acceptance, Ohio con-
tinues to suffer a sovereign-authority injury, since it
must comply with a spending condition that Congress
lacked authority to impose. Pet.App.41a–46a; West
Virginia, 59 F.4th at 1137–38.
Third, Ohio’s having to monitor and prove its com-
pliance with the Tax Mandate inflicts a “compliance-
cost” injury.
2. Whether and when these injuries satisfy the in-
jury-in-fact requirement of Article III depends on the
4
circuit. More precisely, it depends on what the circuit
makes of a regulation that the Treasury promulgated
after the States sued. Coronavirus State and Local
Fiscal Recovery Funds, 86 Fed. Reg. 26786-01, 26810
(May 17, 2021). That regulation—the “Final Rule”—
announces a framework for identifying Tax Mandate
violations. The circuits are split on whether the Final
Rule deprives courts of Article III jurisdiction over
challenges to the Tax Mandate. (Additionally, the
Ninth Circuit held that Arizona had standing to chal-
lenge the Tax Mandate, though its opinion does not
consider the Final Rule. Arizona, 34 F.4th at 848–53
& n.2.)
In the Eleventh Circuit, the Final Rule does not
deprive the States of Article III jurisdiction. In West
Virginia v. Treasury, the circuit held that States sus-
tained at least the imminent-recoupment and sover-
eign-authority injuries before the Final Rule’s prom-
ulgation, giving them Article III standing to sue. 59
F.4th at 1136–38. The Eleventh Circuit further held
that the States are continuing to suffer at least the
sovereign-authority injury as long as they remain sub-
ject to the Tax Mandate; the Final Rule does not, and
cannot, alleviate the Mandate’s “present and continu-
ous infringement on state sovereignty.” Id. at 1136.
Because the States continue to suffer this injury not-
withstanding the Final Rule, that rule did not moot
their challenges.
Ohio would have prevailed under the Eleventh Cir-
cuit’s rule. But it lost in the Sixth Circuit, under logic
the Eleventh Circuit rejected expressly. Compare id.
at 1139, with Kentucky, 54 F.4th at 338–41 and Pet.
App.14a–23a. In the Sixth Circuit’s view, the Final
Rule cured the imminent-recoupment and sovereign-
authority injuries, mooting any case seeking to
5
vindicate those injuries. Pet.App.17a–21a. States
might overcome mootness by proving a compliance-
cost injury. But that injury, the Sixth Circuit held,
must be proved with evidence precisely identifying the
costs sustained from having to monitor and demon-
strate compliance with the Mandate. Kentucky, 54
F.4th at 342–43. Ohio introduced no such evidence, so
the Sixth Circuit deemed its challenge moot.
Pet.App.23a.
Ohio presumably would have lost in the Eighth
Circuit, too. That Court eschewed mootness, and held
that Missouri never even had standing to challenge
the Tax Mandate. Even though the Treasury promul-
gated the Final Rule after Missouri sued, the Eighth
Circuit determined that the rule extinguished the im-
minent-recoupment and sovereign-authority injuries
at the case’s outset. Missouri, 39 F.4th at 1069–70.
(The Eighth Circuit did not address the compliance-
cost theory.)
In sum, three circuits took three different ap-
proaches to Article III jurisdiction in Tax Mandate
challenges. In the Eleventh Circuit, the continuing
nature of the sovereign-authority injury means the Fi-
nal Rule does not moot States’ challenges. In the
Sixth Circuit, these challenges are moot unless record
evidence specifically demonstrates ongoing costs—the
sovereign-authority injury is not enough. And in the
Eighth Circuit, the Final Rule means the States never
had Article III standing to sue.
B. The Secretary concedes the split.
1. The Secretary concedes there is a circuit split,
at least between the Sixth and Eleventh Circuits. See
BIO.14–15. That is reason enough to hear the case:
two circuits are split concerning the important
6
question of whether, and in what circumstances,
States may pursue challenges to the Tax Mandate.
That question is important by itself. See S. Ct. R. 10.
And it is even more important considering that it will
affect the States’ ability to challenge Spending Clause
legislation more broadly.
In any event, the split is deeper than this. Indeed,
the Secretary never denies the analytical split be-
tween the Sixth and Eleventh Circuits on the one
hand, and the Eighth Circuit on the other, regarding
how to analyze the Final Rule’s effect on justiciability.
BIO.12; see also Pet.24–25. The Sixth and Eleventh
Circuits assessed the Final Rule’s relevance through
a mootness lens, while the Eighth considered the issue
through a standing lens. The Secretary dismisses the
significance of this distinction. BIO.12. But this
Court has said the differences between “initial stand-
ing to bring suit” and “postcommencement mootness”
are quite important. Friends of the Earth, Inc. v.
Laidlaw Envtl. Serv., 528 U.S. 167, 174 (2000).
Rightly so. Whereas the plaintiff has the burden of
proving standing to sue, the party urging mootness
has the burden of proving mootness. Pet.24–25. It
thus matters a great deal whether Article III jurisdic-
tion in these cases is resolved through a standing or
mootness rubric.
The Secretary speculates that the Eleventh Circuit
might grant en banc review and align itself with the
Sixth Circuit. BIO.14–15. That would not even re-
solve the just-discussed analytical split, and is un-
likely regardless. The Sixth Circuit, by a seemingly
lopsided vote, rejected a similar invitation to rehear a
Tax Mandate challenge en banc. See Kentucky, 2023
WL 3221058 (order denying rehearing en banc) (not-
ing only four dissenting judges). The Secretary offers
7
no reason to think its en banc petition in the Eleventh
Circuit will fare any better. Indeed, even though the
Secretary petitioned for en banc review on March 31,
the circuit has yet to call for a response. Nor does the
Secretary offer any support for the proposition that
the unlikely possibility of en banc review in a split-
entrenching case counsels against granting a writ of
certiorari.
The Secretary, in urging the Court not to resolve
the circuit split, notes that the Court previously de-
nied Missouri’s certiorari petition in Missouri v.
Yellen. BIO.8. For two reasons, however, the Court’s
denying certiorari in Missouri is uninformative. First,
Missouri’s petition did not present the square split of
authority that Ohio’s does; the Court denied review
three days before the Eleventh Circuit definitively es-
tablished, and then acknowledged, the circuit split.
See Missouri v. Yellen, 143 S. Ct. 734 (2023) (denying
cert.); West Virginia, 59 F.4th at 1124. Second, this is
a better vehicle. Missouri “was ‘not challenging the
Offset Restriction as written, but rather a specific po-
tential interpretation of the provision.’” West Vir-
ginia, 59 F.4th at 1139 (quoting Missouri, 39 F.4th at
1069). In contrast, Ohio is challenging the Offset Re-
striction as written, making this a better vehicle for
addressing the merits question regarding the Tax
Mandate’s constitutionality.
2. The Secretary tries but fails to diminish the
split’s importance. “The fact that” similar disputes
have not arisen before, she says, “confirms” the ques-
tion’s “limited significance.” BIO.15.
That is a peculiar position for the Secretary to
take, as she is seeking en banc review of the jurisdic-
tional issue, see Petn. for En Banc Review at 2 n.1,
8
West Virginia v. Treasury, No. 22-10168, Doc.104-1
(Mar. 6, 2023), and will presumably petition for a writ
of certiorari once the en banc petition fails. Regard-
less, the issue is certainly important. Spending
Clause legislation is the primary means by which the
federal government has seized control over issues con-
stitutionally assigned to the States. The States, and
the legal profession more generally, are beginning to
recognize this. See, e.g., Philip Hamburger, Purchas-
ing Submission: Conditions, Power, and Freedom
124–50 (2021). So the question of when and how the
States may sue to resist the federal government’s
spending-based encroachments is critically im-
portant.
3. Finally, the Secretary argues that the Sixth Cir-
cuit correctly resolved Ohio’s case. BIO.8–11. That is
no reason to deny a petition seeking resolution of a
question that is the subject of a circuit split. This case
presents an opportunity to provide guidance on an im-
portant issue of federal law; Ohio is not seeking mere
error review.
Regardless, the Secretary’s arguments for affir-
mance fail. She fails to show that any of Ohio’s as-
serted injuries—let alone all three—are insufficient
for Article III purposes.
Imminent-recoupment. The Secretary acknowl-
edges that parties have standing to sue for an injunc-
tion of laws that “arguably proscribe[]” their actual or
planned conduct. Susan B. Anthony List, 573 U.S. at
163. But she denies that Ohio faces any credible
threat of enforcement. BIO.9–10. First, she denies
that the Mandate arguably proscribes tax cuts. That
is simply wrong; the Mandate’s vague language argu-
ably empowers the Secretary to recoup Rescue Plan
9
funds from any State that cuts taxes, as at least ten
judges have concluded. See Kentucky, 2023 WL
3221058 at *2 (Bush, J., statement regarding denial
of rehearing en banc); West Virginia, 59 F.4th at 1143–
46; Kentucky, 54 F.4th at 348–53; West Virginia v.
Treasury, 571 F. Supp. 3d 1229, 1250–55 (N.D. Ala.
2021); Pet.App.56a–62a.
The Secretary further argues that the Final Rule
definitively establishes the Secretary’s approach to
enforcing the Mandate, ensuring that Ohio will not
face any recoupment action for a tax cut it has enacted
or plans to enact. BIO.9–10. Not so. The Final Rule
provides little in the way of guidance; it arguably pro-
scribes just about any tax cut, just as the Mandate
does. Kentucky, 54 F.4th at 363 (Nalbandian, J., con-
curring in part and dissenting in part). Indeed, de-
spite purporting to narrow the Mandate’s broad
terms, the Final Rule gives the Secretary almost-lim-
itless authority to initiate recoupment proceedings in
response to any expenditures that she thinks consti-
tute “evasions” of the Tax Mandate. See 31 C.F.R.
§35.4(a); 86 Fed. Reg. at 26821.
Sovereign authority. The Secretary declares that
“requiring States to honor the obligations voluntarily
assumed as a condition of federal funding … simply
does not intrude on their sovereignty.” BIO.10 (brack-
ets omitted) (quoting Bell v. New Jersey, 461 U.S. 773,
790 (1983)). This argument knocks down a straw
man. Ohio has not argued that compliance with a fed-
erally imposed condition always constitutes an injury.
Rather, the injury flows from the fact that Ohio’s tax-
ing authority is limited by a condition from which the
State has a constitutional right to be free. Congress
can use Spending Clause terms to impose conditions
on the States only if it does so “unambiguously,” so
10
that States can “exercise their choice” whether to par-
ticipate in the federal program “knowingly, cognizant
of the consequences of” doing so. Dole, 483 U.S. at 207
(quotation omitted). Ohio was injured when Congress
denied it that opportunity, and it is injured every day
it must comply with an unascertainable limit on its
taxing authority. That the State was coerced into ac-
cepting this unascertainable limit further magnifies
the injury. West Virginia, 59 F.4th at 1136.
Compliance costs. Finally, the Secretary repeats
the Sixth Circuit’s conclusion that, because Ohio must
monitor and report its compliance with the Rescue
Plan generally, it suffers no injury from having to
monitor and report compliance with the Mandate.
BIO.10. “That is a non-sequitur to end all non-se-
quiturs.” Helix Energy Sols. Grp., Inc. v. Hewitt, 598
U.S. 39, 55 n.5 (2023) (prelim. print). The additional
burden of monitoring and reporting compliance with
the Mandate imposes additional costs. The Secretary
faults Ohio for not introducing evidence quantifying
the costs. But Ohio did not need to introduce such ev-
idence. The Rescue Plan and the Final Rule both re-
quire States to monitor and report compliance with
the Mandate. Monitoring and reporting imposes at
least some additional costs. Those additional costs
constitute an injury in fact. The Secretary responds
that Ohio cannot “claim a legally cognizable injury
based on its reallocation of resources toward the rou-
tine administrative task of ensuring compliance with
conditions on the use of federal funds it has voluntar-
ily accepted.” BIO.11. It cites no authority for this
proposition. There is none. Even a “trifle” spent—and
Ohio will necessarily spend at least that monitoring
and reporting compliance—creates an injury in fact.
United States v. Students Challenging Regulatory
11
Agency Procedures 412 U.S. 669, 689 n.14 (1973) (quo-
tation omitted).
II. The Court should decide whether the Tax
Mandate is unconstitutional.
If the Court grants certiorari to decide the jurisdic-
tional question, it should also agree to decide the mer-
its question whether the Tax Mandate is unconstitu-
tional. Pet.31–35. The Secretary disagrees in a sin-
gle, cursory paragraph, arguing that “the Court ordi-
narily does not decide merits questions ‘in the first in-
stance’ where, as here, the court of appeals resolved
the case on threshold grounds.” BIO.15–16 (quoting
Zivotofsky v. Clinton, 566 U.S. 189, 201 (2012)).
Ohio already explained why that ordinary proce-
dure ought not govern here. Pet.33–35. First, because
the States must expend all of their Rescue Plan funds
by 2025, every State will benefit from immediate clar-
ity on the question whether the Secretary may enforce
the Mandate. Pet.34. Second, the merits and juris-
dictional questions overlap significantly, as the Man-
date’s ambiguity bears on both the law’s constitution-
ality and Ohio’s sovereign-authority injury. Id. Fi-
nally, the Court will not have to take a “first view” of
the merits, Zivotofsky, 566 U.S. at 201 (quotation
omitted), in any meaningful sense. Pet.34–35. Two
circuits have held the Tax Mandate unconstitutional
in thoroughly reasoned opinions. And the District
Court’s opinion below is especially scholarly. Addi-
tional proceedings will not aid this Court’s resolution
of the merits.
12
III. At minimum, the Court should hold this
case pending resolution of the Secretary’s
forthcoming petitions.
The Court should grant Ohio’s petition and set the
case for argument in the fall, as this would facilitate a
speedy resolution of the vitally important, time-sensi-
tive merits question. But at minimum, the Court
should hold this case pending the resolution of the
Secretary’s forthcoming certiorari petitions in Ken-
tucky and West Virginia. Ohio’s petition suggested
this possibility. Pet.35–36. The Secretary did not ob-
ject.
CONCLUSION
The Court should grant the petition for a writ of
certiorari and reverse.
Respectfully submitted,
DAVE YOST
Ohio Attorney General
BENJAMIN M. FLOWERS*
Solicitor General
*Counsel of Record
ZACHERY P. KELLER
MATHURA J. SRIDHARAN
Deputy Solicitors General
30 East Broad St., 17th Floor
Columbus, Ohio 43215
614-466-8980
bflowers@ohioago.gov
Counsel for Petitioner
MAY 2023
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