FRANCHISE TAX BOARD OF CALIFORNIA v. HYATT et al.

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488 OCTOBER TERM, 2002
Syllabus
FRANCHISE TAX BOARD OF CALIFORNIA v. HYATT
et al.
certiorari to the supreme court of nevada
No. 02–42. Argued February 24, 2003—Decided April 23, 2003
Respondent Hyatt’s (hereinafter respondent) “part-year” 1991 California
income-tax return represented that he had ceased to be a California
resident and had become a Nevada resident in October 1991, shortly
before he received substantial licensing fees. Petitioner California
Franchise Tax Board (CFTB) determined that he was a California resi-
dent until April 1992, and accordingly issued notices of proposed assess-
ments for 1991 and 1992 and imposed substantial civil fraud penalties.
Respondent filed suit against CFTB in a Nevada state court, alleging
that CFTB had directed numerous contacts at Nevada and had com-
mitted negligence and intentional torts during the course of its audit of
respondent. In its motion for summary judgment or dismissal, CFTB
argued that the state court lacked subject matter jurisdiction because
full faith and credit and other legal principles required that the court
apply California law immunizing CFTB from suit. Upon denial of that
motion, CFTB petitioned the Nevada Supreme Court for a writ of man-
damus ordering dismissal. The latter court ultimately granted the peti-
tion in part and denied it in part, holding that the lower court should
have declined to exercise its jurisdiction over the underlying negligence
claim under comity principles, but that the intentional tort claims could
proceed to trial. Among other things, the court noted that Nevada im-
munizes its state agencies from suits for discretionary acts but not for
intentional torts committed within the course and scope of employment
and held that affording CFTB statutory immunity with respect to inten-
tional torts would contravene Nevada’s interest in protecting its citizens
from injurious intentional torts and bad faith acts committed by sister
States’ government employees.
Held: The Full Faith and Credit Clause, U. S. Const., Art. IV, § 1, does
not require Nevada to give full faith and credit to California’s statutes
providing its tax agency with immunity from suit. The full faith and
credit command “is exacting” with respect to a final judgment rendered
by a court with adjudicatory authority over the subject matter and per-
sons governed by the judgment, Baker v. General Motors Corp., 522
U. S. 222, 233, but is less demanding with respect to choice of laws. The
Clause does not compel a State to substitute the statutes of other States
for its own statutes dealing with a subject matter concerning which it

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Syllabus
is competent to legislate. E. g., Sun Oil Co. v. Wortman, 486 U. S. 717,
722. Nevada is undoubtedly competent to legislate with respect to the
subject matter of the alleged intentional torts here, which, it is claimed,
have injured one of its citizens within its borders. CFTB argues unper-
suasively that this Court should adopt a “new rule” mandating that a
state court extend full faith and credit to a sister State’s statutorily
recaptured sovereign immunity from suit when a refusal to do so would
interfere with the State’s capacity to fulfill its own sovereign responsi-
bilities. The Court has, in the past, appraised and balanced state inter-
ests when invoking the Full Faith and Credit Clause to resolve conflicts
between overlapping laws of coordinate States. See, e. g., Bradford
Elec. Light Co. v. Clapper, 286 U. S. 145. However, this balancing-of-
interests approach quickly proved unsatisfactory and the Court aban-
doned it, Allstate Ins. Co. v. Hague, 449 U. S. 302, 308, n. 10, 322, n. 6,
339, n. 6, recognizing, instead, that it is frequently the case under the
Clause that a court can lawfully apply either the law of one State or the
contrary law of another, Sun Oil Co. v. Wortman, supra, at 727. The
Court has already ruled that the Full Faith and Credit Clause does not
require a forum State to apply a sister State’s sovereign immunity stat-
utes where such application would violate the forum State’s own legiti-
mate public policy. Nevada v. Hall, 440 U. S. 410, 424. There is no
constitutionally significant distinction between the degree to which the
allegedly tortious acts here and in Hall are related to a core sovereign
function. States’ sovereignty interests are not foreign to the full faith
and credit command, but the Court is not presented here with a case in
which a State has exhibited a “policy of hostility to the public Acts” of
a sister State. Carroll v. Lanza, 349 U. S. 408, 413. The Nevada Su-
preme Court sensitively applied comity principles with a healthy regard
for California’s sovereign status, relying on the contours of Nevada’s
own sovereign immunity from suit as a benchmark for its analysis.
Pp. 494–499.
Affirmed.
O’Connor, J., delivered the opinion for a unanimous Court.
Felix E. Leatherwood, Deputy Attorney General of Cali-
fornia, argued the cause for petitioner. With him on the
briefs were Bill Lockyer, Attorney General, Manuel M.
Medeiros, State Solicitor, David S. Chaney, Senior Assistant
Attorney General, and William Dean Freeman, Lead Super-
vising Deputy Attorney General.

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490 FRANCHISE TAX BD. OF CAL. v. HYATT
Opinion of the Court
H. Bartow Farr III argued the cause for respondents.
With him on the brief were Peter C. Bernhard and Donald
J. Kula.*
Justice O’Connor delivered the opinion of the Court.
We granted certiorari to resolve whether the Nevada Su-
preme Court’s refusal to extend full faith and credit to Cali-
fornia’s statute immunizing its tax collection agency from
suit violates Article IV, § 1, of the Constitution. We con-
clude it does not, and we therefore affirm the judgment of
the Nevada Supreme Court.
I
Respondent Gilbert P. Hyatt (hereinafter respondent) filed
a “part-year” resident income tax return in California for
1991. App. to Pet. for Cert. 54. In the return, respondent
represented that as of October 1, 1991, he had ceased to be
a California resident and had become a resident of Nevada.
In 1993, petitioner California Franchise Tax Board (CFTB)
commenced an audit to determine whether respondent had
underpaid state income taxes. Ibid. The audit focused on
*Briefs of amici curiae urging reversal were filed for the State of Flor-
ida et al. by Richard E. Dornan, Attorney General of Florida, Jonathan
A. Glogau, Barbara J. Ritchie, Acting Attorney General of Alaska, and
Thomas R. Keller, Acting Attorney General of Hawaii, and by the Attor-
neys General for their respective jurisdictions as follows: Ken Salazar of
Colorado, Richard Blumenthal of Connecticut, M. Jane Brady of Dela-
ware, James E. Ryan of Illinois, Steve Carter of Indiana, G. Steven Rowe
of Maine, J. Joseph Curran, Jr., of Maryland, Jennifer M. Granholm of
Michigan, Mike Moore of Mississippi, Mike McGrath of Montana, Wayne
Stenehjem of North Dakota, Betty D. Montgomery of Ohio, Anabelle
Rodrı´guez of Puerto Rico, Mark L. Shurtleff of Utah, William H. Sorrell
of Vermont, Jerry W. Kilgore of Virginia, and Darrell V. McGraw, Jr., of
West Virginia; for the Multistate Tax Commission by Frank D. Katz; and
for the National Governors Association et al. by Richard Ruda and James
I. Crowley.
Sharon L. Browne filed a brief for the Pacific Legal Foundation as ami-
cus curiae urging affirmance.

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respondent’s claim that he had changed residency shortly be-
fore receiving substantial licensing fees for certain patented
inventions related to computer technology.
At the conclusion of its audit, CFTB determined that re-
spondent was a California resident until April 3, 1992, and
accordingly issued notices of proposed assessments for in-
come taxes for 1991 and 1992 and imposed substantial civil
fraud penalties. Id., at 56–57, 58–59. Respondent pro-
tested the proposed assessments and penalties in California
through CFTB’s administrative process. See Cal. Rev. &
Tax. Code Ann. §§ 19041, 19044–19046 (West 1994).
On January 6, 1998, with the administrative protest on-
going in California, respondent filed a lawsuit against CFTB
in Nevada in Clark County District Court. Respondent
alleges that CFTB directed “numerous and continuous con-
tacts . . . at Nevada” and committed several torts during the
course of the audit, including invasion of privacy, outrageous
conduct, abuse of process, fraud, and negligent misrepresen-
tation. App. to Pet. for Cert. 51–52, 54. Respondent seeks
punitive and compensatory damages. Id., at 51–52. He
also sought a declaratory judgment “confirm[ing] [his] status
as a Nevada resident effective as of September 26, 1991,”
id., at 51, but the District Court dismissed the claim for lack
of subject matter jurisdiction on April 16, 1999, App. 93–95.
During the discovery phase of the Nevada lawsuit, CFTB
filed a petition in the Nevada Supreme Court for a writ of
mandamus, or in the alternative, for a writ of prohibition,
challenging certain of the District Court’s discovery orders.
While that petition was pending, CFTB filed a motion in the
District Court for summary judgment or, in the alternative,
for dismissal for lack of jurisdiction. CFTB argued that the
District Court lacked subject matter jurisdiction because
principles of sovereign immunity, full faith and credit, choice
of law, comity, and administrative exhaustion all required
that the District Court apply California law, under which:

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“Neither a public entity nor a public employee is liable
for an injury caused by:
“(a) Instituting any judicial or administrative proceeding
or action for or incidental to the assessment or collection
of a tax [or]
“(b) An act or omission in the interpretation or applica-
tion of any law relating to a tax.” Cal. Govt. Code Ann.
§ 860.2 (West 1995).
The District Court denied CFTB’s motion for summary judg-
ment or dismissal, prompting CFTB to file a second petition
in the Nevada Supreme Court. This petition sought a writ
of mandamus ordering the dismissal of the case, or in the
alternative, a writ of prohibition and mandamus limiting the
scope of the suit to claims arising out of conduct that oc-
curred in Nevada.
On June 13, 2001, the Nevada Supreme Court granted
CFTB’s second petition, dismissed the first petition as moot,
and ordered the District Court to enter summary judgment
in favor of CFTB. App. to Pet. for Cert. 38–43. On April
4, 2002, however, the court granted respondent’s petition for
rehearing, vacated its prior ruling, granted CFTB’s second
petition in part, and denied it in part. Id., at 5–18. The
court held that the District Court “should have declined to
exercise its jurisdiction over the underlying negligence claim
under comity principles” but that the intentional tort claims
could proceed to trial. Id., at 7.
The Nevada Supreme Court noted that both Nevada and
California have generally waived their sovereign immunity
from suit in state court and “have extended the waivers to
their state agencies or public employees except when state
statutes expressly provide immunity.” Id., at 9–10 (citing
Nev. Rev. Stat. § 41.031 (1996); Cal. Const., Art. 3, § 5; and
Cal. Govt. Code Ann. § 820 (West 1995)). Whereas Nevada
has not conferred immunity on its state agencies for in-
tentional torts committed within the course and scope of

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employment, the court acknowledged that “California has
expressly provided [CFTB] with complete immunity.” App.
to Pet. for Cert. 10 (citing Cal. Govt. Code Ann. § 860.2
(West 1995) and Mitchell v. Franchise Tax Board, 183 Cal.
App. 3d 1133, 228 Cal. Rptr. 750 (1986)). To determine
which State’s law should apply, the court applied principles
of comity.
Though the Nevada Supreme Court recognized the doc-
trine of comity as “an accommodation policy, under which the
courts of one state voluntarily give effect to the laws and
judicial decisions of another state out of deference and re-
spect, to promote harmonious interstate relations,” the court
also recognized its duty to determine whether the applica-
tion of California law “would contravene Nevada’s policies
or interests,” giving “due regard to the duties, obligations,
rights and convenience of Nevada’s citizens.” App. to Pet.
for Cert. 11. “An investigation is generally considered to be
a discretionary function,” the court observed, “and Nevada
provides its [own] agencies with immunity for the perform-
ance of a discretionary function even if the discretion is
abused.” Id., at 12. “[A]ffording [CFTB] statutory immu-
nity for negligent acts,” the court therefore concluded, “does
not contravene any Nevada interest in this case.” Ibid.
The court accordingly held that “the district court should
have declined to exercise its jurisdiction” over respondent’s
negligence claim under principles of comity. Id., at 7. With
respect to the intentional torts, however, the court held that
“affording [CFTB] statutory immunity . . . does contravene
Nevada’s policies and interests in this case.” Id., at 12. Be-
cause Nevada “does not allow its agencies to claim immunity
for discretionary acts taken in bad faith, or for intentional
torts committed in the course and scope of employment,” the
court held that “Nevada’s interest in protecting its citizens
from injurious intentional torts and bad faith acts committed
by sister states’ government employees” should be accorded

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greater weight “than California’s policy favoring complete
immunity for its taxation agency.” Id., at 12–13.
We granted certiorari to resolve whether Article IV, § 1,
of the Constitution requires Nevada to give full faith and
credit to California’s statute providing its tax agency with
immunity from suit, 537 U. S. 946 (2002), and we now affirm.
II
The Constitution’s Full Faith and Credit Clause provides:
“Full Faith and Credit shall be given in each State to the
public Acts, Records, and judicial Proceedings of every other
State. And the Congress may by general Laws prescribe
the Manner in which such Acts, Records and Proceedings
shall be proved, and the Effect thereof.” Art. IV, § 1. As
we have explained, “[o]ur precedent differentiates the credit
owed to laws (legislative measures and common law) and to
judgments.” Baker v. General Motors Corp., 522 U. S. 222,
232 (1998). Whereas the full faith and credit command “is
exacting” with respect to “[a] final judgment . . . rendered
by a court with adjudicatory authority over the subject mat-
ter and persons governed by the judgment,” id., at 233, it is
less demanding with respect to choice of laws. We have
held that the Full Faith and Credit Clause does not compel
“ ‘a state to substitute the statutes of other states for its own
statutes dealing with a subject matter concerning which it
is competent to legislate.’ ” Sun Oil Co. v. Wortman, 486
U. S. 717, 722 (1988) (quoting Pacific Employers Ins. Co. v.
Industrial Accident Comm’n, 306 U. S. 493, 501 (1939)).
The State of Nevada is undoubtedly “competent to legis-
late” with respect to the subject matter of the alleged inten-
tional torts here, which, it is claimed, have injured one of its
citizens within its borders. “ ‘[F]or a State’s substantive
law to be selected in a constitutionally permissible manner,
that State must have a significant contact or significant ag-
gregation of contacts, creating state interests, such that
choice of its law is neither arbitrary nor fundamentally un-

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fair.’ ” Phillips Petroleum Co. v. Shutts, 472 U. S. 797, 818
(1985) (quoting Allstate Ins. Co. v. Hague, 449 U. S. 302, 312–
313 (1981) (plurality opinion)); see 472 U. S., at 822–823.
Such contacts are manifest in this case: the plaintiff claims
to have suffered injury in Nevada while a resident there; and
it is undisputed that at least some of the conduct alleged to
be tortious occurred in Nevada, Brief for Petitioner 33–34,
n. 16. See, e. g., Carroll v. Lanza, 349 U. S. 408, 413 (1955)
(“The State where the tort occurs certainly has a concern in
the problems following in the wake of the injury”); Pacific
Employers Ins. Co. v. Industrial Accident Comm’n, supra,
at 503 (“Few matters could be deemed more appropriately
the concern of the state in which [an] injury occurs or more
completely within its power”).
CFTB does not contend otherwise. Instead, CFTB urges
this Court to adopt a “new rule” mandating that a state court
extend full faith and credit to a sister State’s statutorily re-
captured sovereign immunity from suit when a refusal to do
so would “interfer[e] with a State’s capacity to fulfill its own
sovereign responsibilities.” Brief for Petitioner 13 (internal
quotation marks omitted).
We have, in the past, appraised and balanced state inter-
ests when invoking the Full Faith and Credit Clause to
resolve conflicts between overlapping laws of coordinate
States. See Bradford Elec. Light Co. v. Clapper, 286 U. S.
145 (1932) (holding that the Constitution required a federal
court sitting in New Hampshire to apply a Vermont workers’
compensation statute in a tort suit brought by the adminis-
trator of a Vermont worker killed in New Hampshire). This
balancing approach quickly proved unsatisfactory. Compare
Alaska Packers Assn. v. Industrial Accident Comm’n of
Cal., 294 U. S. 532, 550 (1935) (holding that a forum State,
which was the place of hiring but not of a claimant’s domicile,
could apply its own law to compensate for an accident in
another State, because “[n]o persuasive reason” was shown
for requiring application of the law of the State where the

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accident occurred), with Pacific Employers Ins. Co. v. Indus-
trial Accident Comm’n, supra, at 504–505 (holding that the
State where an accident occurred could apply its own work-
ers’ compensation law and need not give full faith and credit
to that of the State of hiring and domicile of the employer
and employee). As Justice Robert H. Jackson, recounting
these cases, aptly observed, “it [is] difficult to point to any
field in which the Court has more completely demonstrated
or more candidly confessed the lack of guiding standards
of a legal character than in trying to determine what choice
of law is required by the Constitution.” Full Faith and
Credit—The Lawyer’s Clause of the Constitution, 45 Colum.
L. Rev. 1, 16 (1945).
In light of this experience, we abandoned the balancing-
of-interests approach to conflicts of law under the Full Faith
and Credit Clause. Allstate Ins. Co. v. Hague, 449 U. S., at
308, n. 10 (plurality opinion); id., at 322, n. 6 (Stevens, J.,
concurring in judgment); id., at 339, n. 6 (Powell, J., dissent-
ing). We have recognized, instead, that “it is frequently the
case under the Full Faith and Credit Clause that a court can
lawfully apply either the law of one State or the contrary
law of another.” Sun Oil Co. v. Wortman, supra, at 727.
We thus have held that a State need not “substitute the stat-
utes of other states for its own statutes dealing with a sub-
ject matter concerning which it is competent to legislate.”
Pacific Employers Ins. Co. v. Industrial Accident Comm’n,
supra, at 501; see Baker v. General Motors Corp., supra, at
232; Sun Oil Co. v. Wortman, supra, at 722; Phillips Petro-
leum Co. v. Shutts, supra, at 818–819. Acknowledging this
shift, CFTB contends that this case demonstrates the need
for a new rule under the Full Faith and Credit Clause that
will protect “core sovereignty” interests as expressed in
state statutes delineating the contours of the State’s immu-
nity from suit. Brief for Petitioner 13.
We disagree. We have confronted the question whether
the Full Faith and Credit Clause requires a forum State to

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recognize a sister State’s legislatively recaptured immunity
once before. In Nevada v. Hall, 440 U. S. 410 (1979), an em-
ployee of the University of Nevada was involved in an auto-
mobile accident with California residents, who filed suit in
California and named Nevada as a defendant. The Califor-
nia courts refused to apply a Nevada statute that capped
damages in tort suits against the State on the ground that
“to surrender jurisdiction or to limit respondents’ recovery
to the $25,000 maximum of the Nevada statute would be ob-
noxious to its statutorily based policies of jurisdiction over
nonresident motorists and full recovery.” Id., at 424.
We affirmed, holding, first, that the Constitution does not
confer sovereign immunity on States in the courts of sister
States. Id., at 414–421. Petitioner does not ask us to re-
examine that ruling, and we therefore decline the invitation
of petitioner’s amici States, see Brief for State of Florida
et al. as Amici Curiae 2, to do so. See this Court’s Rule
14.1(a); Mazer v. Stein, 347 U. S. 201, 206, n. 5 (1954) (“We
do not reach for constitutional questions not raised by the
parties”).
The question presented here instead implicates Hall’s sec-
ond holding: that the Full Faith and Credit Clause did not
require California to apply Nevada’s sovereign immunity
statutes where such application would violate California’s
own legitimate public policy. 440 U. S., at 424. The Court
observed in a footnote:
“California’s exercise of jurisdiction in this case poses
no substantial threat to our constitutional system of co-
operative federalism. Suits involving traffic accidents
occurring outside of Nevada could hardly interfere with
Nevada’s capacity to fulfill its own sovereign responsibil-
ities. We have no occasion, in this case, to consider
whether different state policies, either of California or of
Nevada, might require a different analysis or a different
result.” Id., at 424, n. 24.

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CFTB asserts that an analysis of this lawsuit’s effects should
lead to a different result: that the Full Faith and Credit
Clause requires Nevada to apply California’s immunity stat-
ute to avoid interference with California’s “sovereign respon-
sibility” of enforcing its income tax laws. Brief for Peti-
tioner 13.
Our past experience with appraising and balancing state
interests under the Full Faith and Credit Clause counsels
against adopting CFTB’s proposed new rule. Having recog-
nized, in Hall, that a suit against a State in a sister State’s
court “necessarily implicates the power and authority” of
both sovereigns, 440 U. S., at 416, the question of which sov-
ereign interest should be deemed more weighty is not one
that can be easily answered. Yet petitioner’s rule would el-
evate California’s sovereignty interests above those of Ne-
vada, were we to deem this lawsuit an interference with Cal-
ifornia’s “core sovereign responsibilities.” We rejected as
“unsound in principle and unworkable in practice” a rule of
state immunity from federal regulation under the Tenth
Amendment that turned on whether a particular state gov-
ernment function was “integral” or “traditional.” Garcia v.
San Antonio Metropolitan Transit Authority, 469 U. S. 528,
546–547 (1985). CFTB has convinced us of neither the rela-
tive soundness nor the relative practicality of adopting a sim-
ilar distinction here.
Even were we inclined to embark on a course of balancing
States’ competing sovereign interests to resolve conflicts of
laws under the Full Faith and Credit Clause, this case would
not present the occasion to do so. There is no principled
distinction between Nevada’s interests in tort claims arising
out of its university employee’s automobile accident, at issue
in Hall, and California’s interests in the tort claims here aris-
ing out of its tax collection agency’s residency audit. To be
sure, the power to promulgate and enforce income tax laws
is an essential attribute of sovereignty. See Franchise Tax
Bd. of Cal. v. Postal Service, 467 U. S. 512, 523 (1984)

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(“ ‘[T]axes are the life-blood of government’ ” (quoting Bull
v. United States, 295 U. S. 247, 259–260 (1935))). But the
university employee’s educational mission in Hall might also
be so described. Cf. Brown v. Board of Education, 347 U. S.
483, 493 (1954) (“[E]ducation is perhaps the most important
function of state and local governments”).
If we were to compare the degree to which the allegedly
tortious acts here and in Hall are related to a core sovereign
function, we would be left to ponder the relationship be-
tween an automobile accident and educating, on one hand,
and the intrusions alleged here and collecting taxes, on the
other. We discern no constitutionally significant distinction
between these relationships. To the extent CFTB com-
plains of the burdens and expense of out-of-state litigation,
and the diversion of state resources away from the perform-
ance of important state functions, those burdens do not dis-
tinguish this case from any other out-of-state lawsuit against
California or one of its agencies.
States’ sovereignty interests are not foreign to the full
faith and credit command. But we are not presented here
with a case in which a State has exhibited a “policy of hostil-
ity to the public Acts” of a sister State. Carroll v. Lanza,
349 U. S., at 413. The Nevada Supreme Court sensitively
applied principles of comity with a healthy regard for Cali-
fornia’s sovereign status, relying on the contours of Nevada’s
own sovereign immunity from suit as a benchmark for its
analysis. See App. to Pet. for Cert. 10–13.
In short, we heed the lessons learned as a result of Brad-
ford Elec. Light Co. v. Clapper, 286 U. S. 145 (1932), and its
progeny. Without a rudder to steer us, we decline to em-
bark on the constitutional course of balancing coordinate
States’ competing sovereign interests to resolve conflicts of
laws under the Full Faith and Credit Clause.
The judgment of the Nevada Supreme Court is affirmed.
It is so ordered.