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amelia
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attorney
general
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argued
cause
respondents
brief
michael
bowers
attorney
general
perry
michael
executive
assistant
attorney
general
harrison
kohler
deputy
attorney
general
daniel
formby
senior
assistant
attorney
general
warren
calvert
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attorney
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curiae
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state
alabama
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al
mary
sue
terry
attorney
general
virginia
lane
kneedler
chief
deputy
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general
gail
starling
marshall
deputy
attorney
general
peter
low
joined
attorneys
general
respective
state
follows
siegelman
alabama
robert
corbin
arizona
steve
clark
arkansas
duane
woodard
colorado
linley
pearson
indiana
thomas
miller
iowa
william
guste
louisiana
james
tierney
maine
joseph
curran
maryland
hubert
humphrey
iii
minnesota
robert
del
tufo
new
jersey
robert
abrams
new
york
paul
van
dam
utah
jeffrey
amestoy
vermont
hanaway
wisconsin
state
california
et
al
john
van
de
kamp
attorney
general
california
richard
finn
supervising
deputy
attorney
general
eric
coffill
clarine
nardi
riddle
attorney
general
connecticut
robert
butterworth
attorney
general
florida
warren
price
iii
attorney
general
hawaii
james
jones
attorney
general
idaho
frank
kelley
attorney
general
michigan
robert
spire
attorney
general
nebraska
hal
stratton
attorney
general
new
mexico
anthony
celebrezze
attorney
general
ohio
roger
tellinghuisen
attorney
general
south
dakota
paul
van
dam
attorney
general
utah
kenneth
eikenberry
attorney
general
washington
roger
thompkins
attorney
general
west
virginia
donald
hanaway
attorney
general
wisconsin
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council
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governments
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rule
see
bacchus
stevens
dissenting
explaining
new
rule
case
nothing
nature
bacchus
rule
dictates
retroactive
application
negative
commerce
clause
underlies
rule
prohibits
interfering
interstate
commerce
application
bacchus
purpose
fully
served
date
decision
prevented
enacting
similar
tax
schemes
petitioner
james
beam
argues
purposes
commerce
clause
served
fully
unless
bacchus
applied
retroactively
company
contends
retroactive
application
deter
enacting
schemes
argument
fails
decision
bacchus
state
georgia
fully
justified
believing
tax
issue
case
violate
commerce
clause
indeed
bacchus
violate
commerce
clause
imposition
liability
hindsight
state
acting
reasonably
thing
prevent
unconstitutionality
see
american
trucking
opinion
precisely
bacchus
unprecedented
equities
weigh
heavily
retroactive
application
rule
announced
case
state
easily
foresee
invalidation
tax
statutes
reliance
interests
may
merit
little
concern
contrast
state
expected
foresee
decision
overturn
established
precedents
inequity
unsettling
actions
taken
reliance
precedents
apparent
american
trucking
supra
opinion
case
georgia
reasonably
relied
young
market
line
cases
georgia
decision
upholding
predecessor
tax
statute
issue
see
scott
georgia
relying
young
market
indianapolis
brewing
much
weigh
balance
bacchus
legitimate
expectation
james
beam
liquor
manufacturers
pay
tax
issue
constitutional
made
business
decisions
accordingly
little
hardship
companies
receiving
tax
refund
reason
anticipate
equitable
analysis
chevron
oil
places
limitations
liability
may
imposed
unsuspecting
parties
changes
law
james
beam
claims
bacchus
applied
retroactively
georgia
excise
tax
declared
collected
unconstitutionally
state
owes
company
million
refund
app
least
two
identical
refund
actions
pending
georgia
courts
plaintiffs
seek
refunds
almost
million
see
heublein
georgia
civ
action
dekalb
super
apr
joseph
seagram
sons
georgia
civ
action
dekalb
brief
respondents
state
estimates
total
potential
liability
taxed
million
impose
georgia
reasonably
relied
established
precedent
extraordinary
retroactive
liability
time
struggling
fund
even
basic
services
height
unfairness
concerned
state
reaped
unconstitutional
windfall
taxpayers
georgia
collected
good
faith
time
constitutional
tax
subjects
state
potentially
devastating
liability
without
fair
warning
burden
fall
corrupt
state
government
ultimately
blameless
unexpecting
citizens
georgia
form
higher
taxes
reduced
benefits
nothing
jurisprudence
compels
result
traditional
analysis
retroactivity
dictates
fair
application
chevron
oil
analysis
requires
bacchus
applied
retroactively
applied
even
parties
case
mistake
made
today
compounds
problem
imposing
widespread
liability
parties
reason
expect
decision
made
name
equality
stare
decisis
refusing
take
account
settled
expectations
relied
established
precedents
decision
perverts
meaning
terms
respectfully
dissent