The package includes $195 billion for states. But it also has a provision prohibiting states from using any of the money to directly or indirectly offset a reduction in their net revenue through tax cuts or delays in tax increases.

It requires states to return to the federal government any funds that facilitate a tax cut.

Yosts suit argues that since money is fungible any revenue lost by Ohio from a tax cut, credit or other policy enacted by its government would be indirectly offset by the $5.5 billion the state expects to receive” from the federal government.

Thus, the tax mandate effectively prohibits reductions in taxes: any state that reduces taxes, and that experiences a loss in tax revenue, is subject to having billions of dollars in federal funding recouped by the Department of the Treasury,” the suit says.

On Tuesday, more than 20 Republican state attorneys general sent a letter to Treasury Secretary Janet Yellen asking her to confirm by March 23″ that the relief law “does not prohibit states from generally providing tax relief” and that it “simply precludes express use of the relief funds to provide direct tax cuts.

If Yellen balks, they said they will take further appropriate action, without elaborating.