FRANCHISE TAX BD. v. CONSTRUCTION LABORERS VACATION TRUST

No. 82-695.

463 U.S. 1 (1983)

FRANCHISE TAX BOARD OF CALIFORNIA v. CONSTRUCTION LABORERS VACATION TRUST FOR SOUTHERN CALIFORNIA ET AL.

Supreme Court of United States.

Decided June 24, 1983.


Attorney(s) appearing for the Case

Patti S. Kitching, Deputy Attorney General of California, argued the cause for appellant. With her on the briefs were John K. Van De Kamp, Attorney General, and Edmond B. Mamer, Deputy Attorney General.

James P. Watson argued the cause for appellees. With him on the brief were George M. Cox and John S. Miller, Jr.*

Briefs of amici curiae urging affirmance were filed by Solicitor General Lee, Stuart A. Smith, T. Timothy Ryan, Jr., Karen I. Ward, and Allen H. Feldman for the United States; by J. Albert Woll, Laurence Gold, and George Kaufmann for the American Federation of Labor and Congress of Industrial Organizations; by Thomas E. Stanton, Jr., and Victor J. Van Bourg for the Boards of Trustees of the Carpenters Vacation and Holiday Trust Fund for Northern California et al.; and by Eugene B. Granof and George J. Pantos for the ERISA Industry Committee (ERIC).

Joseph I. Lieberman, Attorney General, Christina G. Dunnell, Assistant Attorney General, and Ann Thacher Anderson filed a brief for the State of Connecticut et al. as amici curiae.


JUSTICE BRENNAN delivered the opinion of the Court.

The principal question in dispute between the parties is whether the Employee Retirement Income Security Act of 1974 (ERISA), 88 Stat. 829, as amended, 29 U. S. C. § 1001 et seq. (1976 ed. and Supp. V), permits state tax authorities to collect unpaid state income taxes by levying on funds held in trust for the taxpayers under an ERISA-covered vacation benefit plan...

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