UNITED STATES v. PTASYNSKI

No. 82-1066.

462 U.S. 74 (1983)

UNITED STATES v. PTASYNSKI ET AL.

Supreme Court of United States.

Decided June 6, 1983


Attorney(s) appearing for the Case

Acting Solicitor General Wallace argued the cause for the United States. With him on the briefs were Acting Assistant Attorney General Murray, Stuart A. Smith, Gary R. Allen, and Kristina E. Harrigan.

Stephen F. Williams argued the cause for appellees. With him on the brief for appellees Ptasynski et al. were William H. Brown, Michael J. Sullivan, Robert F. Nagel, and Michael Boudin. Harold B. Scoggins, Jr., and Gary C. Randall filed a brief for appellees Independent Petroleum Association et al. Jim Mattox, Attorney General, David R. Richards, Executive Assistant Attorney General, and Cynthia Marshall Sullivan, Walter Davis, and James R. Meyers, Assistant Attorneys General, filed a brief for appellee State of Texas. Gene W. Lafitte, George J. Domas, Deborah Bahn Price, David B. Kennedy, William H. Mellor III, and Gale A. Norton filed a brief for appellee State of Louisiana.*

Briefs of amici curiae urging affirmance were filed by John J. Rademacher for the American Farm Bureau Federation et al.; by Wilkes C. Robinson for the Gulf & Great Plaines Legal Foundation of America et al.; by David Crump for the Legal Foundation of America et al.; and by Daniel J. Popeo for Senator Don Nickles et al.


JUSTICE POWELL delivered the opinion of the Court.

The issue is whether excluding a geographically defined class of oil from the coverage of the Crude Oil Windfall Profit Tax Act violates the Uniformity Clause.

I

During the 1970's the Executive Branch regulated the price of domestic crude oil. See H. R. Rep. No. 96-304, pp. 4-5 (1979). Depending on its vintage and type, oil was divided into differing classes or tiers and assigned a corresponding...

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