Question juridique clé
Whether the subsidiary constitutional complaint met the strict reasoning requirements.
Solution extraite
No. The complaint did not engage with the cantonal decision’s decisive reasoning and therefore lacked the required detailed constitutional substantiation.
Motifs extraits
In a subsidiary constitutional complaint, only the violation of constitutional rights may be raised and must be specifically argued by reference to the challenged reasoning. A mere general denial of the tax debt is insufficient, especially where the debt itself is no longer reviewable in the debt-enforcement release proceeding.