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Cohn v. Tucson Electric Power Co.

Citations: 138 Ariz. 136; 673 P.2d 334; 1983 Ariz. App. LEXIS 617Docket: No. 2 CA-CIV 4782

Court: Court of Appeals of Arizona; November 30, 1983; Arizona; State Appellate Court

Narrative Opinion Summary

The case involves a dispute between a residential customer and Tucson Electric Power Company (TEP) regarding the payment of an electric bill inclusive of state-imposed taxes. The appellant contended that Article I, Section 10 of the U.S. Constitution mandates state taxes be paid in gold or silver, rather than U.S. currency. He attempted to pay the tax portion of his bill using 'Public Office Money Certificates' (POMCs) as a promissory note, which TEP rejected, leading to a potential termination of service. The trial court issued a temporary restraining order but ultimately dismissed the appellant’s complaint, ruling that TEP is not a state tax agent; thus, the tax is part of the contractual obligation to TEP. The court held that federal reserve notes are legal tender, and the appellant had no legal grounds to refuse payment in U.S. currency. The argument that the Constitution prevents such payment was found to be a misinterpretation, as states cannot create currencies, and Congress regulates legal tender per Norman v. Baltimore, O.R. Co. The decision was affirmed by the appellate court, with Justices Hathaway and Birdsall concurring, upholding the dismissal of the complaint and denial of injunctive relief.

Legal Issues Addressed

Constitutional Restriction on State Currency

Application: The appellant misinterpreted Article I, Section 10 of the Constitution, which prevents states from creating their own currencies and grants Congress the exclusive authority to establish a uniform national currency.

Reasoning: The appellant misinterpreted Article I, Section 10 of the Constitution, which prevents states from creating their own currencies and grants Congress the exclusive authority to establish a uniform national currency.

Contractual Obligations and Tax Components

Application: TEP is not an agent of the state for tax collection; the tax is legally owed by TEP, not the appellant directly. Therefore, the tax component of the bill is part of the contractual obligation to TEP for electricity services.

Reasoning: TEP is not an agent of the state for tax collection; the tax is legally owed by TEP, not the appellant directly. Therefore, the tax component of the bill is part of the contractual obligation to TEP for electricity services.

Legal Tender Status of Federal Reserve Notes

Application: Since federal reserve notes are recognized as legal tender for debts, the appellant has the means to fulfill his payment obligation to TEP.

Reasoning: Since federal reserve notes are recognized as legal tender for debts, the appellant has the means to fulfill his payment obligation to TEP.

Rejection of Non-Legal Tender Instruments

Application: TEP was not required to accept the appellant’s promissory note to the Department of Revenue as payment for the bill, which included portions not due.

Reasoning: TEP was not required to accept the appellant’s promissory note to the Department of Revenue as payment for the bill, which included portions not due.