# Petition — Salorio v. Glaser

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## Record

- **Collection:** Supreme Court brief
- **Document type:** Petition
- **Published:** January 1, 1983
- **Citation:** 464 U.S. 993

## Text

UMCe= SIpreme Court, U.S.

FILED

8 3 = 353 SEP 2 i993

ACEXE Wise L, STEVAS,
CLERK

IN THE

Supreme Court of the United States

OCTOBER TERM, 1983

—
JOHN SALORIO, ROBERT COE and
JOHN D. MCGARR, JR.,
Petitioners,

—_—\ —

SIDNEY GLASER, Director of the Division of Taxation,
Department of the Treasury of the State of New Jersey,

Respondent.

>

PETITION FOR A WRIT OF CERTIORARI TO THE
SUPREME COURT OF THE STATE OF NEW JERSEY

Petitioners John Salorio, Robert Coe and John D. McGarr,
Jr. respectfully pray that a writ of certiorari issue to review the
judgment of the Supreme Court of the State of New Jersey
entered on June 8, 1983.

OPINIONS BELOW

The opinion of the New Jersey Supreme Court, which is not
yet officially reported, appears in Appendix A hereto at Al.
The opinion of the court of first instance (New Jersey Superior
Court, Chanc.ry Division) appears in Appendix B hereto at
A23. A prior opinion of the New Jersey Supreme Court,
remanding the case to the Superior Court, Chancery Division,
for findings of fact, is officially reported at 82 N.J. 482, 414
A.2d 943 (1980).

JURISDICTION

The judgment of the New Jersey Supreme Court was entered
on June 8, 1983. This petition was filed within 90 days
thereafter. This Court's jurisdiction is invoked under 28
U.S.C. § 12$7(3).

Statutory and Constitutional Provisions Involved

New Jersey Emergency Transportation Tax Act (Commuter
Income Tax), $54 N.J. Stat. Ann. §§ 8A-1-8A-57 (West Supp.
1983).

Reprinted in Appendix D to this Petition for Certiorari.

U.S. Const., Art. IV. § 2, el. 1

“The Citizens of each State shall be entitled to all
Privileges and Immunities of Citizens in the several
States.”

Statement of the Case

A. Preliminary Statement

Petitioners are citizens and residents of the State of New
York who work or who have worked in the State of New
Jersey, and who have therefore been subject to New Jersey’s
Commuter Income Tax, which falls exclusively on New
Yorkers. Although the Commuter Income Tax is indistinguish-
able from the discriminatory commuter tax struck down under
the Privileges and Immunities Clause in Austin v. New
Hampshire, 420 U.S. 656 (1975), petitioners were required to
expend more than six years in the New Jersey State courts
relitigating precisely the issue decided in Austin. Until the New
Jersey Supreme Court finally held, in June 1983, that the
Commuter Income Tax violates the Privileges and Immunities
Clause, the State of New Jersey continued to collect the
unconstitutional tax.

The New Jersey Supreme Court nevertheless applied its
ruling prospectively only, and refused to award petitioners any
refunds of taxes paid after the date of the Austin decision. By
postponing the effective date of its decision to January 1, 1984,
the Court permitted the State to reap a substantial windfall,
and sanctioned its defiance of this Court’s decree. If permitted
to stand, this aspect of the judgment of the Court below will be
a clear signal to state and local governments that the risks
entailed by ignoring this Court’s decisions are minimal. The
states will conclude that even plainly unconstitutional statutes
may be counted on to raise revenue until the judicial process
ends and the legislation is invalidated.

This Court should therefore grant certiorari to protect the
integrity of stare decisis in constitutional litigation.

B. New Jersey's Commuter Income Tax

Pursuant to the Commuter Income Tax, first enacted in
1961, New Jersey has taxed New York residents who derive
income in or from the State of New Jersey at rates that range
from 2% to 15% of taxable income. New Jersey residents,
however, paid no income tax whatsoever on their income
derived from New Jersey until 1976, and since that time have
paid income taxes of 2% to 3%, under a separate tax called the
New Jersey Gross Income Tax.!

While New Jersey residents are theoretically subject to the
Commuter Income Tax,’ only New York residents pay the tax

| New Yorkers working in New Jersey are subject to the Gross Income
Tax as well as the Commuter Income Tax, and are required to pay
whichever tax results in the higher levy,

2 By its terms, the Commuter Income Tax is imposed (a) upon
residents of New Jersey on their income earned in another “critical
area state” and (b) upon a// income—including rents, capital gains,
and so forth—derived from New Jersey by persons who are not
residents of New Jersey but who reside in a “critical area state.” 54
N.J. Stat. Ann, § 8A-2 (West Supp. 1983). A “critical area state” is one
bordering on New Jersey as to which the State Highway Commissioner

4

in practice. The statute provides New Jersey residents working
in New York with a credit against the Commuter Income Tax
for income taxes which they pay to New York. 54 N.J. Stat.
Ann. § 8A-16 (West Supp. 1983). Since New York's income tax
is identical in rate with the Commuter Income Tax, New Jersey
residents who work in New York pay income taxes to New
York which necessarily equal the Commuter Income Tax; they
therefore eceive a full credit and pay no Commuter Income
Tax to New Jersey. Thus, no New Jersey resident has ever paid
a penny under this tax. Indeed, New Jersey residents have been
exempted from filing returns for the Commuter Income Tax.
54.N.J. Stat. Ann. § 8A-19(b) (West Supp. 1983); [1980] 1 N.J.
Tax Reporter (CCH) §§ 18-301, 305.

The New Jersey Commuter Income Tax on New York resi-
dents is, and has been since its inception, identical in all
Significant respects with the New York State income tax. For
example, the rate table for the Commuter Income Tax is a
carbon copy of the rate table for New York’s income tax as set
out in the New York statute books.’ Not only are the ta. sates
and structures of the two taxes identical, but each time New
York has amended its income tax statute in any significant
respect, New Jersey has shortly thereafter enacted an identical
change.

Significant to the analysis required by Austin v. New
Hampshire, 420 U.S. 656 (1975), New Jersey does not impose
any tax which is payable by New Jersey citizens alone—all of
New Jersey’s other taxes are imposed upon residents and
nonresidents alike.

has certified that there exists a “critical transportation problem”
relating to the commutation between New Jersey and the bordering
state. 54. N.J. Stat. Ann. § 8A-S (West Supp. 1983).

The only “critical area” which has ever been certified is the New
York-New Jersey border. Therefore, residents of New York who work
in New Jersey and New Jersey residents who work in New York are
theoretically subject to the Commuter Income Tax.

3 Compare 1978 N.J. Sess. Laws, Ch. 131, with $9 New York Tax Law
§ 602 (McKinney 1982) and 1978 N.Y. Sess. Laws, Ch. 70.

The purported justification for the Commuter Income Tax is
the burden that nonresident commuters allegedly place upon
New Jersey’s transportation facilities. But the tax has never
been adjusted during its entire twenty year history to reflect
any transportation needs or burdens; its rates are set solely to
conform with New York’s statute. Indeed, Governor Meyner,
in his original message to the New Jersey legislature, candidly
stated that the intent of the statute was to take advantage of
tax credits granted by New York State’s income tax scheme and
divert tax revenues from New York. See, Day, Taxing Interstate
Commuters: A New Jersey Experimeni Under The United
States Constitution, 18 Rutgers L. Rev. 1, 2 (1963).*

Moreover, imposition of the tax is not limited to New
Yorkers who actually commute to New Jersey; rather, the tax is
levied on ail income derived by New Yorkers from New Jersey,
including rents and capital gains, whether or not the New York
resident ever sets foot in New Jersey. Yet neither Connecticut
nor New Jersey residents who use the very same transportation
facilities are taxed.

The New Jersey tax is identical in all significant respects to
the discriminatory commuter tax invalidated by this Court in
Austin v. New Hampshire, 420 U.S. 656 (1975).

—Each commuter income tax is a duplicate of the income
tax imposed by the bordering state;

—Each was designed to, and has the effect of, taking
advantage of tax credits granted by the bordering state in order
to divert income tax revenues from that bordering state;

—Each is nominally imposed on residents and nonresidents,
but, by means of credits or exemptions, in fact is imposed only
on nonresidents;

4 While the proceeds of the tax assertedly are kept in a special fund
for transportation projects, 54 N.J. Stat. Ann. §§ 8A-20-23 (West
Supp. 1983), transfers from that fund may be and have been made
regularly to the State’s General Fund and to the Property Tax Relief
Fund. See $4 N.J. Stat. Ann. § 8A-121 (West Supp. 1983).

6

—Each taxing state requires employers to withhold portions
of the nonresidents’ income for payment of the commuter
income tax;

—Each commuter income tax “falls exclusively on the in-
come of nonresidents; and it is not offset even approximately
by other taxes imposed upon residents alone.” Austin v. New
Hampshire, 429 U.S. at 665.°

This Court concluded that the New Hampshire tax could be
upheld only if, looking to “the practical effect and operation”
of the taxing scheme, “the nonresident was not treated more
onerously than the resident in any particular, and in fact was
called upon to make no more than his ratable contribution to
the support of the state government.” 420 U.S. at 664 (empha-
sis added).

Although New Hampshire attempted to argue that the tax
did not discriminate at all between Maine and New Hampshire
citizens, this Court ruled flatly that the New Hampshire tax
could not be sustained under the principle of “substantial
equality of treatment,” because the “tax falls exclusively on the
income of nonresidents; and it is not offset even approximately
by other taxes imposed upon residents alone.” 420 U.S. at 665.

The discriminatory effect of the New Jersey Commuter
Income Tax is identical with that of the invalid New
Hampshire tax. The New Jersey Commuter Income Tax falls
only on nonresidents—in this case, only New Yorkers—and the
tax on New York residents’ income (up to 15% of taxable
income) is not even approximately offset by taxes that New
Jersey has imposed only upon its own residents.

5 In this and other respects, the New Jersey Commuter Income Tax is
worse than the New Hampshire tax invalidated in Austin. New
Hampshire residents did pay some taxes to which nonresidents were
not subjected. See Austin v. New Hampshire, 420 U.S. at 659 n. 3.
Moreover, the maximum rate paid by Maine residents in Austin was
4%, whereas the Commuter Income Tax imposed on New Yorkers has
ranged as high as 15%.

The State of New Jersey recognized that the constitutional
fate of its statute was inextricably tied to that of the New
Hampshire tax. Thus, New Jersey submitted an amicus brief to
this Court in Austin (on behalf of New Hampshire) which
conceded that the two states’ commuter income tax schemes
were “similar.” See Amicus Curiae Brief of the Attorney
General of the State of New Jersey at 3, Austin v. New
Hampshire, 420 U.S. 656 (1975). The New Jersey Supreme
Court has also stated that “[t]he mechanics of the [Commuter
Income Tax] are strikingly similar to the invalidated New
Hampshire tax.” Salorio v. Glaser, 82 N.J. 482, 504 n.17, 414
A.2d 943, 953 n.17 (1980). And in evident recognition of the
constitutional infir.nities of its tax in the wake of Austin, the
proceeds of the tax were held separate for a period of at least
two years pending the outcome of this challenge to the tax, and
were disbursed only at the end of each fiscal year.

C. New Jersey’s Evasion of this Court’s Decree in Austin

Austin therefore clearly foreshadowed—indeed, com-
pelled—a ruling that the Commuter Income Tax contravenes
the Privileges and Immunities Clause. Yet New Jersey managed
to stave off compliance with the teaching of this Court for
more than six years, meanwhile collecting as much as $40
million each year from citizens of New York.

After substantial dilatory and frivolous motion practice,°
which helped to delay the case for over a year before the merits
could even be addressed, the State attempted to distinguish

6 Thus, for example, the State (1) moved to dismiss the case for failure
to exhaust administrative remedies—in the face of uniform authority
holding that no exhaustion is necessary in a constitutional challenge to
a statute; (2) moved to dismiss for failure to join New York State as a
“real party in interest,” even though New Jersey previously had
argued—and this Court had held—that only individual citizens, and
not the State of New York, had standing, New York v. New Jersey, 429
U.S. 810 (1976); and (3) moved to dismiss on the ground that plaintiffs
lacked standing—on precisely the same argument raised and squarely
rejected in Austin v. New Hampshire, 420 U.S. at 659-60 n. 4.

Austin on the ground that the tax is justified by the costs New
Yorkers impose on New Jersey’s transportation facilities. Yet
such a justification must be meaningless as a matter of law. By
definition, a nonresident who works in a neighboring state and
thereby earns income can do so only by transporting himself
there. This interstate commutation necessarily will impose
some cost or “burden” upon the transportation facilities of the
taxing state. Austin necessarily presented precisely the same
problem, and therefore must be read to hold that the “trans-
portation problem” created by the mere movement of residents
of one state to work in a neighboring state cannot serve as a
legitimate justification for a discriminatory tax. Otherwise,
Austin would be a nullity.

And this “cost” justification was frivolous as a matter of
fact as well. For not only had the tax been enacted and
modified solely to capture income from New York, and in
disregard of any transportation cost issues (see pp. 3-5, supra),
but the State was unable to advance any evidence at the five
day hearing on this matter that New Yorkers constituted the
“peculiar source” of the alleged transportation problem,
Toomer v. Witsell, 334 U.S. 385, 398 (1948); Hicklin v.
Orbeck, 437 U.S. 518, 526-27 (1978), or that there was a
“substantial relationship” between the burdens New Yorkers
imposed on the transportation system and the discrimination
practiced against them. See Toomer v. Witsell, 334 U.S. at
398-99. Indeed, how could it have done so? As the New Jersey
Supreme Court noted, “New Jersey to New York commuters
substantially outnumber those travelling from New York to
New Jersey,” and New Yorkers constitute a tiny fraction—
2.9% in 1970 and 4.0% in 1980—of the total number of
interstate and intrastate commuters using New Jersey’s facili-
ties. See Appendix A at Al2.’ New Yorkers thus travel against

7 Between 1962-1980, the tax generated $381 million from New
Yorkers. Yet, even according to the State’s own testimony, there was a
gross disparity between the sums collected and the costs attributable to
New York commuters. The New Jersey Supreme Court assumed
witout deciding that the State was correct that New Yorkers paid

9

the peak flow of traffic, which consists of New Jerseyans
commuting to New York.

Recognizing that the tax could not be justified under Austin
by reference to the additional costs New Yorkers impose on
New Jersey’s transportation facilities, the State essentially
abandoned its attempt to defend the tax on this ground, and
instead concocted a novel—and incoherent— “benefits” theory,
which was ultimately, and properly, rejected by the New Jersey
Supreme Court (Appendix A at All). On this theory, New
York commuters (like any other user of New Jersey transporta-
tion facilities) receive some theoretical total amount of “bene-
fits” from travelling on New Jersey roads (such as reduced
travel time and savings on tire wear); the dollar amount of
such benefits is necessarily a multiple of the costs imposed by
New Yorkers; and New York commuters may be taxed in an
amount equivalent to these theoretical “benefits”. But New
Jersey taxes its own residents on the basis of costs it incurs,
and not on benefits New Jerseyans enjoy; the State does not
make a profit off its citizens. On the State’s theory, however,
since the dollar amount of benefits exceeds the dollar amount
of transportation costs, New Jersey can make a profit, but
only off New York commuters.”

twice as much in taxes as the costs attributable to them, because the
Court concluded that the Privileges and Immunities Clause was vio-
lated by a disparity of this magnitude. The record below demonstrates
clearly, however, that the proceeds of the tax were actually between
nine and thirty times higher than maximum state and local government
transportation expenditures that could conceivably be s*tributed to
New Yorkers. Indeed, New Yorkers’ payments under ™.w Jersey's
gasoline tax alone more than covered their share of any state transpor-
tation costs.

8 In any event, the “benefits” test is purely tautological—a New
Yorker's share of benefits is precisely the same as his share of costs; the
State measured both on the basis of percentage of use of transporta-
tion facilities. New York commuters represent only about 1% of total
usage of transport facilities, and yet their tax payments are many times
more than 1% of total payments for transportation in New Jersey. As
the trial court recognized, on the State’s theory, New Yorkers must pay

10

In short, as was clear from the outset of this litigation, and
as the New Jersey Supreme Court ultimately held, New Jer-
sey’s “transportation” justification for its discriminatory tax
was a makeweight which could not withstand serious analysis.
But by ruling that its decision voiding the Commuter Income
Tax would be afforded prospective effect only, and that peti-
tioners would not be awarded refunds of taxes paid to the State
since Austin, the New Jersey Supreme Court rewarded the
State for gambling that it would not be penalized for failing to
comply with a controlling precedent of this Court.

REASONS FOR GRANTING THE WRIT

THIS COURT SHOULD GRANT THE WRIT TO RE-
STRAIN THE INVOCATION OF THE PROSPECTIVITY
DOCTRINE AS A DEVICE FOR AVOIDING STARE DECI-
SIS, AND TO ENSURE THAT STATES DO NOT CON.-
TINUE TO ENFORCE UNCONSTITUTIONAL REVENUE
STATUTES BECAUSE OF A BELIEF THAT RETROSPEC-
TIVE RELIEF WILL RARELY, IF EVER, BE AWARDED.

Before a rule of law can be afforded prospective effect only,
it is well-settled that

“(t]he decision to be applied nonretroactively must estab-
lish a new principle of law, either by overruling clear past
precedent on which litigants may have relied, or by
deciding an issue of first impression whose resolution was
not clearly foreshadowed.”

Chevron Oil Co. v. Huson, 404 U.S. 97, 106 (1971) (citations
omitted). The justification for limiting prospectivity to cases
that announce a new legal standard is that any other rule
would vitiate the rule of stare decisis and undermine the role of
this Court as the ultimate arbiter of questions of constitutional

a dollar for each dollar of benefit, while New Jersey residents pay no
more than 12-16 cents for the same dollar of benefit. (See Appendix B
at A30.)

dimensions. Retrospective application of established legal prin-
ciples through damage awards is what gives this Court some
assurance that, by and large, its decisions will actually govern
the behavior of persons in similar circumstances.’ Such assur-
ance is of particular significance because of the practical
inability of the courts—and of this Court in particular—to
provide review of every statute of dubious constitutional valid-
ity.

Vigilant monitoring by this Court is especially necessary
when the doctrine of prospectivity, designed as a shield against
unexpectedly harsh or unjust results when a new legal principle
is announced, is instead invoked to avoid the impact of
controlling precedent. Prospectivity then becomes a sword. It
cuts off relief to which persons injured by a clearly unconstitu-
tional statute are entitled, destroys incentives to challenge
unconstitutional enactments, and removes the deterrent effect
of damage awards on unconstitutional conduct. That, we
submit, is what has happened in this case.

Once this Court had decided Austin v. New Hampshire in
1975, there was no reasonable basis for believing that the New
Jersey Commuter Income Tax could pass constitutional muster.
The tax should have been declared unconstitutional on its face
in a summary proceeding. Rather than acknowledge that tre
Austin decision controlled, however, New Jersey continued to
enforce its facially invalid statute while the litigation lan-
guished in the state court system for nearly six years.’ And by

9 As Professor Mishkin pointed out almost twenty years ago, retro-
active application of holdings that can be “reasonably anticipated”
helps insure that those who may be affected by such holdings will seek
to conform, in advance, to expected standards. Mishkin, The Supreme
Court, 1964 Term-Foreword: The High Court, The Great Writ, and
Due Process of Time and Law, 79 Harv. L. Rev. $6, 72 (1965).

10 It should be pointed out that New Jersey is not the first state that
has sought to retain the benefits of invalid tax legislation. Historians
have documented numerous instances in which governments have
collected taxes under clearly unlawful statutes. See O. Field, The
Effect of an Unconstitutional Statute 318-320 (1935).

12

1980, when the New Jersey Supreme Court ruled that the State
had the burden of proof, New Jersey could not possibly argue
that it was relying on the presume! constitutionality of a
legislative act. Salorio v. Glaser, 82 N.J. 482, 503-504, 414
A.2d 943, 953-54 (1980). Yet, New Jersey reaped as much as
$40 million per year exclusively from New Yorkers, who had
no voice in the legislative affairs of New Jersey and whose
interests were entirely unrepresented there.''

By permitting New Jersey to retain the tax revenues it
obtained from New Yorkers and postponing the effectiveness
of its decision to strike down the statute until 1984, the New
Jersey Supreme Court’s judgment tells the states that it is to
their advantage to enact revenue statutes without regard to
their constitutionality. Legislatures can be secure in the knowl-
edge that, even if their unconstitutional laws are ultimately

11 Granting the writ is particularly appropriate in this case because
Salorio concerns a state tax that contravenes the Privileges and
Immunities Clause. Non-residents of a state who are subject to a
discriminatory tax can generally challenge its constitutionality only in
state court. See Tax Injunction Act, 28 U.S.C. § 1341 (1976). State
court judges, however, are understandably reluctant to void a tax that
constitutes a substantial source of revenue for the state. The original
New Jersey trial judge in this case, for instance, candidly stated on a
number of occasions that he was struggling for a way to uphold the
tax, despite Austin. He said, for example: “[I]f I could find a way to
end it or to avoid Austin, | surely would sustain this tax... .”
Transcript of Proceedings, Salovio v. Glaser, No. C-3628-76 (N.J.
Super. Ct. Ch. Div. Feb. 23, 1978) at 16.

The reluctance to void an unconstitutional iax may extend to a
reluctance to apply any such decision retroactively. As this Court
recognized in Lemon v. Kurtzman, 411 U.S. 192, 200 n. 2 (1973),
however, constitutional interests cannot be ignored in deciding whether
to attach retrospective effect to a constitutional decision. This Court
should take this oprortunity to reemphasize the importance of the
values embodied in the Privileges and Immunities Clause and the
appropriateness of securing these values by awarding damages for a
clear violation of the principles of Austin. Where a state's financal
self-interest is implicated, this Court has been particularly vigilant in
protecting constitutional principles. See United States Trust Co. v.
New Jersey, 431 U.S. 1, 25-26 (1977).

13
invalidated, the states will be able to retain any revenues they
received in the interim.

Such a misconception will affect more than economic in-
terests. It will impede the operation of the Privileges and
Immunities Clause itself. See, Chevron Oil Co. v. Huson, 404
U.S. at 106-107 (“we must . . . weigh the merits and demerits
in each case by looking to the prior history of the rule in
question, its purpose and effect, and whether retrospective
Operation will further or retard its operation”). Even the
temporary enforcement of comparable legislation will have a
substantially harmful impact on the ability of thousands of
persons like petitioners to travel and pursue their occupations
in neighboring states free from discriminatory treatment. It
will also disrupt the structural integrity of our federal system
by encouraging the passage of retaliatory legislation by the
home states of commuters. See Austin v. New Hampshire, 420
U.S. at 662. Retrospective application of the Salorio decision
to require refunds of taxes paid since 1975, when Austin was
decided, or since 1980, when the New Jersey Supreme Court
placed on the State the burden of proof to justify the tax, will
substantially advance the underlying purposes of the Privileges
and Immurities Clause.

The New Jersey Supreme Court’s justification for declining
to give its ruling retrospective effect was that it was announc-
ing “a new rule of law” and that the State had reasonably
relied on the revenues derived from the tax until such time as it
was declared invalid (Appendix A at Al7-A18). To be sure,
this Court has, on several occasions, held that prospective
application of a decision was appropriate when an issue of first
impression had been decided. See, e.g., Lemon v. Kurtzman,
411 U.S. 192, 206 (1973).

But this is not such a case. Austin v. New Hampshire not
only foreshadowed, but compelled, the invalidation of the
Commuter Income Tax. As this Court noted recently in United
States v. Johnson, 457 U.S. 537, 549 (1982):

“when a decision of this Court merely has applied settled
precedents to new and different factual situations, no real

14

question has arisen as to wivether the later decision should
apply retrospectively. In such cases, it has been a foregone
conclusion that the rule of the later case applies in earlier
cases, because the later decision has not in fact altered
that rule in any material way.”

Under such circumstances, this Court simply will not hear it
argued that reliance has been placed on the unconstitutional
statute; such a “rule would mean that every such unconstitu-
tional statute, like every dog, gets one bite, if anyone has relied
on the statute to his detriment.” New York v. Cathedral
Academy, 434 U.S. 125, 130 (1977).

To permit the prospective aspect of the judgment below to
stand would, in a very direct way, undermine the importance of
stare decisis in constitutional litigation, and remove a signifi-
cant constraint on the states’ willingness to enact revenue
legislation that impinges on clearly articulated and entrenched
constitutional! values. If the State of New Jersey is permitted to
retain the tax revenues it collected in defiance of this Court’s
decision in Austin, the carefully delimited doctrine of prospec-
tivity will have engulfed the general principle that settled rules
of law should be afforded retrospective effect.

CONCLUSION

For the reasons set forth above, a writ of certiorari should
issue to review the prospective aspect of the judgment of the
Supreme Court of New Jersey.

September 2, 1983
Respectfully submitted,

Max Gitter
Adrian M. Foley, Jr.
Of Counsel: Counsel for Petitioners

Richard A. Rosen
Kevin J. Coakley

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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40385011_0353%3A1. Public record. Not legal advice.