Seminole Tribe of Florida v. State of Florida Department of Revenue, 750 F.3d 1238

Seminole Tribe of Florida seeks declaratory relief and refunds for fuel taxes paid to fuel suppliers, challenging taxes on off-tribal-land purchases and use on tribal lands.
Florida precollects the fuel tax from suppliers and labels the legal incidence as on the ultimate consumer, with refunds available to exempt consumers.
The Tribe argues the tax violates the Indian Commerce Clause, Indian sovereignty, and Equal Protection because it taxes fuel expended on tribal lands for essential government services.
Florida defines 'use' of fuel as placing fuel into a vehicle, affecting whether exemptions apply to Tribe purchases.
The Tribe previously sued in state court (2004–2006 taxes) and lost, then filed a federal suit (2009–2012 taxes); the district court dismissed for Rooker-Feldman and Tax Injunction Act grounds and did not address sovereign immunity.
The majority holds that Florida has sovereign immunity from the suit, making the Department and its Director immune; Ex parte Young does not permit relief here because the requested relief is equivalent to a state-funded refund.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does Eleventh Amendment sovereign immunity bar the Tribe’s federal suit against Florida officials?	Seminole argues for relief against state officers despite immunity.	Florida asserts immunity applies to both Department and Director.	Yes; sovereign immunity bars the suit against both Department and Director.
Are Counts I–II (declaratory judgment that fuel tax exemptions apply) permissible under Ex parte Young?	Counts I–II seek prospective declaratory relief against officials for ongoing unconstitutional tax.	Relief would be a state-funded refund, not permissible under Ex parte Young.	No; Ex parte Young does not authorize relief because it would be a state-funded monetary remedy.
Do TIA or Rooker-Feldman block the Tribe’s federal claims?	Tribe contends federal review is possible under Moe and independent federal questions.	District court erred by applying Rooker-Feldman/TIA to bar relief.	The district court need not address these if sovereign immunity suffices to bar the suit.
Is the Department the real party in interest for purposes of sovereign immunity?	N/A (Tribe asserts a state officer should be liable personally under Ex parte Young).	The Department, not the Director, is the real party in interest, so immunity applies.	The Department is the real party in interest; immunity applies.

Rooker v. Fidelity Trust Co., 263 U.S. 413 (U.S. 1923) (limits federal review of state-court judgments)
D.C. Court of Appeals v. Feldman, 460 U.S. 462 (U.S. 1983) (precludes federal review of state-court decisions)
Edelman v. Jordan, 415 U.S. 651 (U.S. 1974) (retroactive monetary relief barred from state treasury; Ex parte Young limits)
Ford Motor Co. v. Department of Treasury of Indiana, 323 U.S. 459 (U.S. 1945) (suits against state officials for refunds can be barred as against the state)
Seminole Tribe of Fla. v. Florida, 517 U.S. 44 (U.S. 1996) (Eleventh Amendment sovereign immunity and Indian sovereignty limits)
Ex parte Young, 209 U.S. 123 (U.S. 1908) (allows prospective relief against state officers to enjoin unconstitutional conduct)
Moe v. Confederated Salish & Kootenai Tribes, 425 U.S. 463 (U.S. 1976) (TIA exclusion for tribal suits under 28 U.S.C. § 1362)
CSX Transp., Inc. v. Bd. of Pub. Works of W. Va., 138 F.3d 537 (4th Cir. 1998) (injunction against future collection is prospective relief)
Blatchford v. Native Village of Noatak, 501 U.S. 775 (U.S. 1991) (limits on state tax injunctions and Ex parte Young applicability)
Muscogee (Creek) Nation v. Pruitt, 669 F.3d 1159 (10th Cir. 2012) (prospective challenges to state taxation by tribes)