Rojas v. United States
- 3:24-cv-04075
- U.S. District Court · Northern District of California
- 3
In Rojas v. United States, the court dismissed the tax challenge for lack of jurisdiction under the Anti-Injunction Act and denied motions as moot.
The dismissal ended Cesar A. Rojas and Greysa Ramirez’s attempt in this case to stop federal tax collection and obtain damages from the United States and the Internal Revenue Service. The ruling addressed jurisdiction and did not reach the government’s other dismissal arguments or the merits of the plaintiffs’ tax theories.
What happened
In Rojas v. United States, Cesar A. Rojas and Greysa Ramirez sought to stop the United States and the Internal Revenue Service from collecting federal income taxes and requested damages. They argued that the Ninth and Sixteenth Amendments excused them from paying those taxes.
The government moved to dismiss, arguing that the case was barred and that the court lacked jurisdiction, among other grounds. The plaintiffs did not respond to the government’s motions.
The court dismissed the complaint for lack of subject-matter jurisdiction under the Anti-Injunction Act and said the Declaratory Judgment Act also barred the claims. Judge information is not provided in the opinion. The court denied the government’s motion to dismiss and the plaintiffs’ motion for a permanent injunction as moot, and closed the case.
The detailed version
- Rojas v. United States · No. 3:24-cv-04075
- Oct. 4, 2024
Background
Cesar A. Rojas and Greysa Ramirez sued the United States and the Internal Revenue Service. They sought an injunction—an order requiring or prohibiting conduct—to stop the defendants from collecting federal income taxes. They also sought compensatory and punitive damages. Their arguments included that they were not required to pay federal income taxes under the Ninth and Sixteenth Amendments.
The plaintiffs had previously filed a related case involving similar arguments and tax-collection relief. They then filed this case and moved for a permanent injunction. The government moved to dismiss, arguing that the case was barred by prior-judgment doctrines, that the court lacked subject-matter jurisdiction, that the plaintiffs had not stated a legally valid claim, and that they were not entitled to equitable relief. The plaintiffs did not respond to the government’s motions.
Jurisdiction ruling
The court held that the Anti-Injunction Act prevented the plaintiffs from bringing this action. That statute generally bars suits seeking to restrain the assessment or collection of a tax. The court said the plaintiffs had not shown either of the exceptions discussed in the opinion: irreparable injury or certainty of success on the merits. The plaintiffs instead argued that the IRS’s attempt to tax them was illegal and unconstitutional, which the court found insufficient to establish an exception.
The court also stated that the Declaratory Judgment Act bars federal courts from granting declaratory relief concerning federal taxes and does not itself provide subject-matter jurisdiction. Because the court lacked jurisdiction, it declined to consider the government’s other three arguments for dismissal.
Disposition
The court DISMISSED the plaintiffs’ complaint for lack of subject-matter jurisdiction. It DENIED as moot the government’s Motion to Dismiss and the plaintiffs’ Motion for Permanent Injunction. The Clerk was ordered to close the case, and the scheduled hearing was vacated. The opinion does not identify the judge by name.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.