Colonial Pipeline Co. v. Morgan

OPINION

CLAY, Circuit Judge.

Colonial Pipeline Company (“Colonial”) appeals the district court’s dismissal of its complaint under Fed.R.Civ.P. 12(b)(1) for lack of subject matter jurisdiction. Colonial challenges the constitutionality of Tennessee’s statutory scheme for classifying real and personal property for purposes of ad valorem tax assessment under the Equal Protection Clause of the Fourteenth Amendment of the United States Constitution; Article I, Section 8, Clause 3 (the Commerce Clause) of the United States Constitution; Article VI, Clause 2 (the Supremacy Clause) of the United States…