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United States v. Burke, 504 U.S. 229 (1992)
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General SummaryThis case is from a collection containing the full text of over 16,000 Supreme Court cases from 1793 to the present. The body of Supreme Court decisions are, effectively, the final interpretation of the Constitution. Only an amendment to the Constitution can permanently overturn an interpretation and this has happened only four times in American history.
United States v. Burke, 504 U.S. 229 (1992)
United States v. Burke No. 91-42 Argued Jan. 21, 1992 Decided May 26, 1992 504 U.S. 229
CERTIORARI TO THE UNITED STATES COURT OF APPEALS
FOR THE SIXTH CIRCUIT
Syllabus
As part of the settlement of a sex discrimination claim under Title VII of the Civil Rights Act of 1964, the Tennessee Valley Authority (TVA) paid backpay to affected employees, including respondents, from which it withheld federal income taxes. The Internal Revenue Service (IRS) disallowed respondents’ claims for refund of the withheld taxes. In a subsequent refund action, the District Court ruled that, since respondents had obtained only backpay due them as a result of TVA’s discriminatory underpayments. rather than compensatory or other damages, the settlement proceeds could not be excluded from their gross incomes as "damages received . . . on account of personal injuries" under 26 U.S.C. § 104(a)(2). The Court of Appeals reversed, holding that TVA’s discrimination constituted a personal, tort-like injury to respondents, and rejecting the Government’s attempt to distinguish Title VII, which authorizes no compensatory or punitive damages, from other statutes thought to redress personal injuries.
Held: Backpay awards in settlement of Title VII claims are not excludable from gross income under § 104(a)(2). Pp. 233-242.
(a) IRS regulations formally link identification of a "personal injury" for purposes of § 104(a)(2) to traditional tort principles, referring to "prosecution of a legal suit or action based upon tort or tort type rights." 26 CFR § 1.104-1(c). In order to fall within the § 104(a)(2) exclusion, respondents must show that Title VII, the legal basis for their recovery of backpay, redresses a tort-like personal injury. Pp. 233-234.
(b) A hallmark of traditional tort liability is the availability of a broad range of damages to compensate the plaintiff for harm sustained. Title VII, however, permits the award of only backpay and other injunctive relief. Congress sought through Title VII to restore victims to the wage and employment positions they would have occupied absent discrimination, but declined, in contrast to other federal antidiscrimination statutes, to recompense victims for any of the other traditional harms associated with personal injury, such as pain and suffering, emotional distress, harm to reputation, or other consequential damages. Thus, Title VII cannot be said to redress a tort-like personal injury within the meaning of § 104(a)(2) and the applicable regulations. Pp. 234-242.
929 F.2d 1119 (CA6 1991), reversed.
BLACKMUN, J., delivered the opinion of the Court, in which REHNQUIST, C.J., and WHITE, STEVENS, and KENNEDY, JJ., joined. SCALIA, J., post, p. 242, and SOUTER, J., post, p. 246, filed opinions concurring in the judgment. O’CONNOR, J., filed a dissenting opinion, in which THOMAS, J., joined, post, p. 248.
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Chicago: U.S. Supreme Court, "Syllabus," United States v. Burke, 504 U.S. 229 (1992) in 504 U.S. 229 504 U.S. 230. Original Sources, accessed November 25, 2024, http://originalsources.com/Document.aspx?DocID=MV4LJ4BA7782R2J.
MLA: U.S. Supreme Court. "Syllabus." United States v. Burke, 504 U.S. 229 (1992), in 504 U.S. 229, page 504 U.S. 230. Original Sources. 25 Nov. 2024. http://originalsources.com/Document.aspx?DocID=MV4LJ4BA7782R2J.
Harvard: U.S. Supreme Court, 'Syllabus' in United States v. Burke, 504 U.S. 229 (1992). cited in 1992, 504 U.S. 229, pp.504 U.S. 230. Original Sources, retrieved 25 November 2024, from http://originalsources.com/Document.aspx?DocID=MV4LJ4BA7782R2J.
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