Colon de Mejias v. Lamont, No. 18-3533 (2d Cir. 2020)
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Plaintiffs appealed the district court's grant of summary judgment in favor of defendants in an action claiming that Connecticut's Public Act 17-2, as amended by Public Act 18-81, which transfers money from the state's legislatively created energy funds to the general purpose fund, violates the Contract and Equal Protection Clauses of the United States Constitution.
The Second Circuit affirmed the district court's determination that plaintiffs had no contractual right to prevent the transfer of money to the general purpose fund and that the Act is an allocation of state revenue, not a tax, so that the taxpayer standing doctrine bars plaintiffs' claim. In this case, plaintiffs do not have a contractual right to control transfers from the Energy Fund and thus plaintiffs have failed to plead a violation of the Contract Clause.
The court also held that because the transfer of previously collected revenue from the Energy Funds to the General Fund is not a transfer of plaintiffs' property to the state, it cannot constitute a tax. The court explained that, at its core, plaintiffs' argument is that funds previously collected for green energy and conservation initiatives will now be expended for another use, but taxpayers do not have standing to challenge such expenditures. Therefore, the court held that plaintiffs have no standing to proceed with their Equal Protection claim.
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