Franchise Tax Board v. Construction Laborers Vacation Trust
United States Supreme Court
463 U.S. 1 (1983)
CLVT (defendant) administered a construction-industry vacation trust plan qualifying as an ERISA employee welfare benefit plan. California's Franchise Tax Board (plaintiff) sued CLVT in state court to enforce a state law requiring anyone holding a taxpayer's property to withhold and remit unpaid taxes, seeking $380.56 plus a declaration that CLVT must comply with future tax levies. CLVT removed the case to federal court, arguing ERISA preempted the state levy; the district court denied remand and rejected the ERISA-preemption defense on the merits, but the appellate court reversed, and after a denied rehearing petition renewing the jurisdictional argument, the Board appealed to the Supreme Court.
Whether a federal court may exercise federal-question jurisdiction under 28 U.S.C. Section 1331 over a state-law claim merely because the defendant intends to raise a federal preemption defense, as opposed to federal law itself creating the cause of action or the plaintiff's right to relief depending on a substantial federal question.