WASHINGTON -- In a closely watched case from Georgia, the U.S. Supreme Court yesterday ducked the issue of whether states must provide refunds on unconstitutionally collected taxes.

But the court's splintered decision, delivered by Justice David H. Souter, may leave cash-strapped states across the country liable for billions of dollars of refunds because the ruling held that Supreme Court decisions on the constitutionality of taxes and other actions must be applied retroactively unless barred by procedural requirements.

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