In 1992 in Quill Corp. v. North Dakota, the Court held that states cannot require retailers with no in-state physical presence to collect use tax.  Since 2010, Colorado has required remote sellers to inform Colorado purchasers annually of their purchases and send the same information to the Colorado Department of Revenue.  The Direct Marketing Association sued Colorado in federal court claiming these requirements are unconstitutional under Quill.  The Court held unanimously in Direct Marketing Association v. Brohl that the Tax Injunction Act (TIA) does not bar a federal court from deciding this case.  Per the TIA, that federal courts may not “enjoin, suspend or restrain the assessment, levy or collection of any tax under State law” where a remedy is available in state court.  The TIA was modelled on the Anti-Injunction Act, which concerns federal taxes.  According to the Court, “the Federal Tax Code has long treated information gathering as a phase of tax administration that occurs before assessment, levy, or collection.”  And, while DMA’s lawsuit sought to “limit, restrict, or hold back” tax collection in Colorado, it did not “restrain” tax collection in the narrow sense— by stopping it.