545 U.S. 308, 318 (2005)
In 1994, the Internal Revenue Service seized real property in Michigan belonging to Grable & Sons Metal Products, Inc., to satisfy the company's federal tax delinquency.1
The IRS provided notice of the seizure to Grable by certified mail, which Grable received before selling the property to Darue Engineering & Manufacturing.2 Grable did not redeem the property within the 180-day statutory period following the sale. After that period had passed, the Government gave Darue a quitclaim deed.3
Five years later, Grable brought a quiet title action in Michigan state court against Darue.4 Grable claimed that Darue’s record title was invalid because the IRS had failed to notify Grable of its seizure of the property in the exact manner required by federal statute.5 Grable asserted that the statute required personal service rather than service by certified mail.6
Darue removed the case to the United States District Court for the Western District of Michigan.7 The district court declined to remand after finding that the claim posed a significant question of federal law and granted summary judgment to Darue.8 The Court of Appeals for the Sixth Circuit affirmed.9 The Supreme Court granted certiorari on the jurisdictional question alone.10
Whether the want of a federal cause of action to try claims of title to land obtained at a federal tax sale precludes removal to federal court of a state action with nondiverse parties raising a disputed issue of federal title law?11
Federal-question jurisdiction under 28 U.S.C. § 1331 extends to a state-law claim that necessarily raises a stated federal issue, actually disputed and substantial, which a federal forum may entertain without disturbing any congressionally approved balance of federal and state judicial responsibilities.12
No. Grable's quiet title action in Michigan state court necessarily raised the disputed meaning of the federal tax notice statute as an essential element of its claim of superior title.13 The federal issue is substantial.14 The national interest in the prompt collection of delinquent taxes requires clear terms of notice to protect buyers at tax sales and to allow the IRS to satisfy its claims from property of delinquents.15 Federal jurisdiction over such rare state title cases implicating contested federal tax provisions would have only a microscopic effect on the division of labor between state and federal courts.16 The absence of a federal cause of action is relevant to the substantiality inquiry and to congressional intent but is not dispositive.17
Merrell Dow retained the contextual Smith inquiry rather than converting a federal right of action into a necessary condition for jurisdiction.18
The want of a federal cause of action does not preclude removal to federal court of the state quiet title action raising a disputed and substantial issue of federal tax law.19
Related opinions on this issue
Justice Thomas concurred in the judgment.20 He observed that the Court faithfully applied precedents interpreting 28 U.S.C. § 1331 to authorize federal-court jurisdiction over some cases in which state law creates the cause of action but requires determination of an issue of federal law.21 No party asked the Court to overrule those precedents and adopt the rule Justice Holmes set forth in American Well Works Co. v. Layne & Bowler Co.22 The Smith standard is anything but clear.23
Justice Thomas expressed willingness to reconsider the interpretation of § 1331 in an appropriate case with better evidence of the original meaning of the statute.24