This educational guide is based on the linked primary sources. It is not a Court publication, is not affiliated with the Court, and is not legal advice.
In brief
Overview
Background and question before the Court
What each side argues
EC Term of Years Trust (Petitioner)
According to Petitioner, the Defendant, in unequivocal language of section 1346, waives sovereign immunity and permits a refund suit by a third party such as Petitioner.
United States (Government) (Respondent)
The Government contended that Mrs. Williams had remedies available to her, certainly not a levy, because there was no levy, but the Government was contending she could have sought relief under the Quiet Title Act.
Ms. Maynard (Respondent)
According to Ms. Maynard, when Congress creates a specific remedy for a specific situation that remedy forecloses resort to a more general remedy when that general remedy would frustrate the purposes of the specific remedy.
What happened at oral argument
Justice Ginsburg asked: “And why did the court point out twice in Williams that section 7426 was not available?”
Justice Breyer asked: “You want to say no to that.”
Justice Scalia asked: “Was, was the more specific statute there enacted after the more general statute?”
What the Court decided
Why it matters
Terms to know
No glossary terms are available for this guide.
Primary sources
Read the source materials on the official site or open the immutable repository copy used for this guide.
- 231e90b269367f8bb7d6-r1-6be202812f376528.pdforal argument transcript
Guide generated September 21, 2026. Automated validation accepted this version.