Christian Coalition of Florida, Inc. v. United States
662 F.3d 1182
11th Cir.2011Background
- CC-FL sought a tax refund for 1991 and 1994-2000 and sought declaratory/injunctive relief on tax-exempt status.
- IRS refunded some years (2005-2006 fully; others partially) and later the district court dismissed as moot.
- IRS determined CC-FL was not a 501(c)(4) tax-exempt; final determination letter issued July 31, 2008.
- CC-FL filed suit April 3, 2009; refunds ultimately sent August 11, 2009, with six-month lookback period for remaining years.
- Court held post-refund forward-looking relief is barred by Anti-Injunction Act and DJA, rendering case moot.
- Court noted Congress created limited refund-review scheme and did not provide DJA/AIA exceptions for 501(c)(4) status claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| May CC-FL obtain declaratory/injunctive relief after full refund? | CC-FL can pursue post-refund relief despite AIA/DJA. | AIA/DJA bar forward-looking relief once refund granted. | Bar applies; no jurisdiction for forward-looking relief. |
| Do collateral consequences create a live controversy after refund? | Collateral effects keep controversy alive about future status. | Consequences do not override AIA/DJA mootness. | Collateral consequences insufficient to overcome mootness. |
| Is the case capable of repetition yet evading review? | Issue may recur with future tax years and status. | Each year is a new liability; not evading review for same plaintiff. | Not meet the two-prong MOOTNESS exception. |
| Does voluntary cessation by the IRS preserve jurisdiction? | IRS cessation was voluntary and should not moot the case. | Refunds compelled by statute, not voluntary cessation; mootness stands. | Not satisfied; refunds were statutory, not voluntary cessation. |
Key Cases Cited
- Bob Jones Univ. v. Simon, 416 U.S. 725 (Supreme Court, 1974) (AIA bars pre-enforcement tax suits; refund action preferred)
- Enochs v. Williams Packing & Navigation Co., 370 U.S. 1 (Supreme Court, 1962) (two-prong exception to mootness for injunctive relief needs irreparable harm and no likelihood of success)
- Harrell v. The Florida Bar, 608 F.3d 1241 (11th Cir., 2010) (voluntary cessation framework for mootness burden on defendant)
- City of Los Angeles v. Lyons, 461 U.S. 95 (Supreme Court, 1983) (capable-of-repetition yet evading review doctrine requires live controversy)
- Sunnen v. Commissioner, 333 U.S. 591 (Supreme Court, 1948) (income tax controversies originate per year; separate liabilities per year)
- Murphy v. Hunt, 455 U.S. 478 (Supreme Court, 1982) (same controversy must recur with reasonable expectation to avoid mootness)