context: Lower federal courts have recognized that the statute codified the prior adequacy standard.
citation_a.signal: see
citation_a.identifier: 538 F. 2d 67, 67
citation_a.parenthetical: "the decisions indicate that 'plain, speedy and efficient' means no more than the prior equity standard of 'adequacy' "
citation_a.sentence: See Garrett v. Bamford, 538 F. 2d, at 67 ("the decisions indicate that 'plain, speedy and efficient’ means no more than the prior equity standard of 'adequacy’ ”); Dillon v. Montana, 634 F. 2d 463, 466-467 (CA9 1980) (recognizing that Congress gave explicit sanction to pre-existing equity practice and stating that "[t]he remedial certainty contemplated by § 1341 is that a state forum be empowered to consider claims that a tax is unlawful and to issue adequate relief”); United Gas Pipe Line Co. v. Whitman, 595 F. 2d 323, 325 (CA5 1979) (“Since the 1937 statute was intended as a codification of judicial practice prior to its passage, both the Supreme Court and this court have found it useful to draw on the background of pre-1937 decisions in interpreting the purposes and policies which underlie it”); Charles R. Shepherd, Inc. v. Monaghan, 256 F. 2d 882, 884 (CA5 1958) (federal court has no jurisdiction under the Tax Injunction Act if “an adequate remedy is provided for the recovery back if improperly collected”); see also Louisville & Nashville R. Co. v. Public Service Comm’n, 631 F. 2d 426 (CA6 1980) (state remedy limited to seeking upward revision of other taxpayers’ assessments did not bar federal-court jurisdiction under § 1341), cert.. denied, post, p. 959; Alnoa G.
citation_b.signal: see also
citation_b.parenthetical: state remedy limited to seeking upward revision of other taxpayers' assessments did not bar federal-court jurisdiction under SS 1341
citation_b.sentence: See Garrett v. Bamford, 538 F. 2d, at 67 ("the decisions indicate that 'plain, speedy and efficient’ means no more than the prior equity standard of 'adequacy’ ”); Dillon v. Montana, 634 F. 2d 463, 466-467 (CA9 1980) (recognizing that Congress gave explicit sanction to pre-existing equity practice and stating that "[t]he remedial certainty contemplated by § 1341 is that a state forum be empowered to consider claims that a tax is unlawful and to issue adequate relief”); United Gas Pipe Line Co. v. Whitman, 595 F. 2d 323, 325 (CA5 1979) (“Since the 1937 statute was intended as a codification of judicial practice prior to its passage, both the Supreme Court and this court have found it useful to draw on the background of pre-1937 decisions in interpreting the purposes and policies which underlie it”); Charles R. Shepherd, Inc. v. Monaghan, 256 F. 2d 882, 884 (CA5 1958) (federal court has no jurisdiction under the Tax Injunction Act if “an adequate remedy is provided for the recovery back if improperly collected”); see also Louisville & Nashville R. Co. v. Public Service Comm’n, 631 F. 2d 426 (CA6 1980) (state remedy limited to seeking upward revision of other taxpayers’ assessments did not bar federal-court jurisdiction under § 1341), cert.. denied, post, p. 959; Alnoa G.