TCEEA v. Rodriguez (Makko Oko)
| TCEEA v. Rodriguez | |
|---|---|
 | |
| Court | Supreme Court, Opposh, Makko Oko |
| Decided | August 7, 2025 |
| Case history | |
| Appealed from | Appellate Court of Appeals of Makko Oko |
| Case opinions | |
| The Tax Litigation Court is a civil body meant for usage by accountants and by the tax authority, it is not a body for criminal conduct to be heard and judged. The court has weighed the authority of the court in its ruling against the defendants' rights and have found that their Section 4 rights under the Constitution were violated in whole. No court shall try any person criminally without following the constructs set out in the Constitution and statute, and this court has violated such constructs. Lower court's judgement overturned, case remanded to Tax Litigation Court. | |
| Majority | Graham, Sparks, Aponte |
| Dissent | Gerlach, Reynolds |
TCEEA v. Rodriguez is a case that was decided by the Supreme Court of Makko Oko on August 7th, 2025 on rather the Tax Litigation Court has the jurisdiction to try citizens criminally for any cases under their purview. The case would go on to set a wide-reaching precedent on the authorities of administrative courts in enforcing statute and in enforcing laws embedded within them.
Background
Amando Rodriguez was a small business owner from Xuzilvuis in the small city of Rul, Taupo, Makko Oko. When Rodriguez filed his annual tax return in 2025, he had attested to the source of all income received and spent for his business, however, the TCEEA opened an inquiry and later began to audit their finances, with a lawsuit being filed against them in Tax Litigation Court in July, citing violations of the reporting requirements set out under the BPA, and accused him and his business of money laundering. Rodriguez, representing himself pro se, had argued that the court had no jurisdiction to enforce the BPA, arguing that "Laundering and liability are crimes, and this court has no power to assert itself in a criminal manner over me". The court disagreed, and Rodriguez ended up losing. With the TCEEA now threatening asset seizure, Rodriguez appealed to the Appellate Court of Appeals and later successfully to the Supreme Court.
Decision
The court ruled 3-1-2 in favor of Rodriguez, with the majority opinion written by Justice Sparks. The majority opinion cited that Section 4 of the Constitution was violated, so even if the court had the jurisdiction to assert itself in such a manner over the defendant, the entire prosecution and every ruling they made was unconstitutional. The decision had the wide-reaching effect of severely limiting the administrative courts, including the Tax Litigation Court in itself, in being able to pursue justice and enforce statute ratified by the government.
Effects
This case led to the ratification of the Administrative Courts Act of 2025, which explicitly defined the powers of administrative courts and set out who has the authority to create them. While the ACA did not specifically solve the issue of civil tax enforcement, the Tax Litigation Court would be able to use this act to later pursue Rodriguez on the same charges. As for agency enforcement of statute, and their use of their own courts and tribunals to do so, that would not be resolved until 2027 when a coalition of council members came together and compromised to ratify the Alternative Criminal Enforcement Act, which would establish the Civil Cases Enforcement Commission as an independent government agency to approve criminal cases to be charged in a civil manner, and further reformed how administrative courts were to handle civil and criminal enforcement.
Immediately after the ruling, the case saw the TCEEA halt all enforcement operations temporarily, lasting until November 2025 when they resumed operations following the ratification of the Administrative Courts Act of 2025. All future cases done by the TCEEA in Tax Litigation Court from here on would require first a criminal conviction, which would have to be heard in criminal courts, and then the TCEEA could pursue them civilly in Tax Litigation Court because they only had civil jurisdiction according to both the Administrative Courts Act and the Supreme Court.
