Jenkins v. Washington Convention Center

Argued September 8, 2000 Appellants, who are 19 individuals and one corporation,1 seek refunds of special District of Columbia taxes enacted by the Council of the District of Columbia (""D.C. Council"") to finance a new convention center. They alleged in their complaint that the Mayor exceeded his authority under the District of Columbia Self-Government and Governmental Reorganization Act2 by collecting the special taxes under an expired statute, and that, notwithstanding later ratifications of the taxes by the D.C. Council, they were deprived of property without procedural due process and just compensation. They also alleged tortious conversion of their money. The district court dismissed the complaint for lack of subject matter jurisdiction. On appeal, appellants contend that the district court erred in holding that the District of Columbia is a ""State"" for purposes of the Federal Tax Injunction Act, 28 U.S.C. § 1341 (1994) (""FTIA""), that the FTIA barred their claims under 42 U.S.C. § 1983 (Supp. III 1997), and that their claims may only be presented in the Superior Court of the District of Columbia after exhaustion of administrative remedies. We need not decide whether the FTIA applies to the District of Columbia, nor whether the FTIA bars appellants' claim for monetary damages under § 1983. Because Congress has granted exclusive jurisdiction over challenges to District of Columbia tax assessments to the District of Columbia courts, see D.C. Code §§ 11-921(a)(3)(B), 11-1201, 11-1202 (1981), we affirm the dismissal of the complaint for lack of subject matter jurisdiction.3