Michael L. Patterson v. Gladwin Corporation

Summary

The court held that a class action seeking refunds from the State treasury for franchise taxes collected under an invalid statutory scheme was barred by sovereign immunity and presented a subject-matter jurisdiction defect. It concluded that compliance with the Taxpayers' Bill of Rights was the exclusive and jurisdictional method for obtaining a franchise-tax refund, and that requiring use of that procedure did not violate federal due process through a bait-and-switch. The court vacated the class-certification order and dismissed the action.