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COLONIAL PIPELINE CO. v. MORGAN

No. 06-5220.

474 F.3d 211 (2007)

COLONIAL PIPELINE COMPANY, Plaintiff-Appellant, v. John G. MORGAN, Tennessee Comptroller of the Treasury, Individually and as a Member of the Tennessee State Board of Equalization, et al., Defendants-Appellees.

United States Court of Appeals, Sixth Circuit.

Decided and Filed: January 9, 2007.

Attorney(s) appearing for the Case

ARGUED: Ron L. Quigley, Davis, Matthews & Quigley, Atlanta, Georgia, for Appellant. Charles L. Lewis, Office of the Attorney General, Nashville, Tennessee, for Appellees. ON BRIEF: Ron L. Quigley, Davis, Matthews & Quigley, Atlanta, Georgia, for Appellant. Charles L. Lewis, Office of the Attorney General, Nashville, Tennessee, for Appellees.

Before MOORE and CLAY, Circuit Judges; BELL, Chief District Judge.

OPINION

CLAY, Circuit Judge.

Colonial Pipeline Company ("Colonial") appeals the district court's dismissal of its complaint under Fed.R.Civ.P. 12(b)(1) for lack of subject matter jurisdiction. Colonial challenges the constitutionality of Tennessee's statutory scheme for classifying real and personal property for purposes of ad valorem tax assessment under the Equal Protection Clause of the Fourteenth Amendment of the United States Constitution; Article...

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