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MAINE MEDICAL CENTER v. U.S.

No. 11-1426.

675 F.3d 110 (2012)

MAINE MEDICAL CENTER, Plaintiff, Appellant, v. UNITED STATES, Defendant, Appellee.

United States Court of Appeals, First Circuit.

Decided March 30, 2012.

Attorney(s) appearing for the Case

Robert H. Stier, Jr. , with whom Shelli Li Calland , Joshua D. Dunlap , Michael A. Schlanger , Covington & Burling LLP, and Pierce Atwood LLP were on brief, for appellant.

Robert William Metzler , Attorney, Tax Division, Department of Justice, with whom Tamara W. Ashford , Deputy Assistant United States Attorney, Ellen Page DelSole , John A. Dudeck, Jr. , and Stephen T. Lyons were on brief, for appellee.

Before LYNCH, Chief Judge, SOUTER, Associate Justice, and STAHL, Circuit Judge.

STAHL, Circuit Judge.

Maine Medical Center's (MMC) tax refund suit stalled when the district court found that jurisdictional discovery was not warranted and that without such discovery, MMC could not meet its burden of demonstrating jurisdiction. MMC appealed the district court's judgment for the government, arguing that it had offered sufficient evidence to merit jurisdictional discovery. Ultimately, MMC did not make an adequate threshold showing that its refund...

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