California ex rel. Deukmejian v. Regan

SKOPIL, Circuit Judge:

INTRODUCTION

California sought declaratory and injunctive relief from the requirement that it file an annual information return with the Internal Revenue Service (“IRS”) pursuant to the Employee Retirement Income Security Act (“ERISA”) provision governing employee pension benefit plans. 26 U.S.C. § 6058(a). California argued that Congress did not intend for ERISA to apply to governmental plans, and that if Congress did so intend, that application violates the tenth amendment.

The IRS argued that California’s claim was barred by the Anti-Injunction Act, 26 U.S.C. § 7421(a),…