The ruling ended a long tax dispute between Gilbert Hyatt and California regarding alleged tax fraud by Hyatt. Hyatt had been challenging the tax fraud penalties that the California Franchise Tax Board (FTB) had ordered him to pay since 1993, both in court and through administrative proceedings. Because of the Supreme Court ruling, Hyatt was required to pay for all legal costs he incurred, without receiving a judgement against the FTB. On this matter, Justice Clarence Thomas wrote: "The consequences for the inventor are that he'll suffer the loss of two decades of litigation expenses and a final judgment against the Board for its egregious conduct. ... Those case-specific costs are not among the reliance interests that would persuade us to adhere to an incorrect resolution of an important constitutional question."
