Cuno v. DaimlerChrysler, Inc., 386 F.3d 738 (6th Cir. 2004), cert. granted, Nos. 04-1704 & 04-1724, is scheduled for oral argument in the Supreme Court on March 1, 2006.  The case involves the constitutionality of Ohio’s investment tax credit (as well as the procedural question of Respondents’ standing).

I previously posted (here) the merits briefs of Daimler Chrysler and the State of Ohio, as well as supporting amici briefs, thanks to the gneerosity of Stephen P. Carney and Ada L. Marginean of Ohio Attorney General Jim Petro’s Office.  I am delighted to make available now the merits brief of the Respondent, Charoltte Cuno and other taxpayers of Toledo, OH, and supporting amici briefs, thanks to the generosity of Peter D. Enrich (Northeastern), one of Respondent’s counsel.

Merits Brief in Support of Charlotte Cuno

Amici Briefs in Support of Charlotte Cuno:

• Center on Budget and Policy Priorities (Part I, Part II, and Part III)
• Economics and Public Policy Professors
• Fiscal Policy Institute, Connecticut Policy Institute, Connecticut Voices for Children, and Good Jibs First
• North Carolina Institute for Constitutional Law

Merits Briefs in Support of Daimler Chrysler and the State of Ohio:

• DaimlerChrysler
• State of Ohio

Amici Briefs in Support of Daimler Chrysler and the State of Ohio:

• AlphaGenics, Inc., Greater Baltimore Technology Council, MdBio, Inc., Technology Council of Maryland, Upsate Venture Association of New York, Inc., and 20/20 Genesytems, Inc.
• Ashbrook Center for Public Affairs
• City of New York
• Council on State Taxation and National Association of Manufacturers
• Ford and GM
• National Governors Association, National league of Cities, International Municipal Lawyers Association, Council of State Governments, National Association of Counties, National Conference of State Legislators, U.S. Conference of Mayors, Government Finance Officers Association, and International City/County Management Association
• Nissan
• Pacific Legal Foundation
• Tax Executives Institute, Inc.
• Tax Foundation
• The Right Place, Inc. and the City of Grand Rapids, MI
• Thirty-Four States (AL, AZ, AR, CA, CO, CT, DE, GA, HA, ID, IL, IN, IA, KY, ME, MD, MA, MI, MO, NE, NV, NY, ND, OK, OR, PA, SC, SD, TN, TX, UT, VT, WA, WI)
• Washington Legal Foundation
• Wayne County, MI

Amici Briefs Supporting Neither Party:

• DirecTV, Inc. and Echostar Satellite LLC