Rollins Hudig Hall of Rhode Island, Inc. v. Clark

Although I join the Court’s opinion, I write separately to amplify the reasons why I believe we should affirm the District Court’s judgment in all respects, except for its treatment of the prejudgment-interest issue. In my opinion, the tax administrator lacked the authority and the requisite factual basis to tax $3,281,487.545 to the respondent, insurance-broker Rollins Hudig Hall of Rhode Island, Inc. (Hall-RI), for allegedly procuring certain, surplus-line insurance covering the aviation-liability risks of its client, Textron, Inc. (Textron), a Rhode Island insured. This tax represented 3…