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United States Ninth Circuit

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Fredrickson v. Starbucks Corp., 13-36067

In a class action brought by three former baristas at Starbucks, challenging defendant's practice of withholding state and federal taxes from baristas' paychecks based on cash tips received, the district court's dismissal with prejudice is reversed and the case remanded to state court where: 1) the Tax Injunction Act and the Anti-Injunction Act deprives the district court of subject matter jurisdiction over plaintiffs' claims for declaratory and injunctive relief; and 2) the federal-state comity doctrine bars the district court from awarding statutory damages on the state-tax component of the plaintiffs' claims.

Appellate Information

  • Decided
  • Published 2016/11/03




  • United States Ninth Circuit


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