Con. Law I Final Cases

Pollock v. Farmers' Loan & Trust Co. (1895)

Facts of the case The Constitution gave the states the power to impose direct taxation. The federal government could impose direct taxes as well, but only if those taxes were apportioned among the states in proportion to their representation in Congress. In this case, the Court examined the Income Tax Act of 1894. Question Was the income tax a direct tax in violation of the Constitution (Article I, Section 9)? Conclusion The Court held that the Act violated the Constitution since it imposed taxes on personal income derived from real estate investments and personal property such as stocks and bonds; this was a direct taxation scheme, not apportioned properly among the states. The decision was negated by the adoption of the Sixteenth Amendment in 1913.

Gibbons v. Ogden (1824)

Facts of the case A New York state law gave Robert R. Livingston and Robert Fulton a 20-year monopoly over navigation on waters within state jurisdiction. Aaron Ogden and other competitors tried to forestall the monopoly, but Livingston and Fulton largely succeeded in selling franchise or buying competitors' boats. Thomas Gibbons -- a steamboat owner who did business between New York and New Jersey under a federal coastal license - formed a partnership with Ogden, which fell apart after three years when Gibbons operated another steamboat on a New York route belonging to Ogden. Ogden filed suit against Gibbons in New York state court, and received a permanent injunction The New York state court rejected Gibbons' argument asserting that U.S. Congress controlled interstate commerce. Question Does the Commerce Clause give Congress authority over interstate navigation? Conclusion Justice Marshall concluded that regulation of navigation by steamboat operators and others for purposes of conducting interstate commerce was a power reserved to and exercised by the Congress under the Commerce Clause. As interstate navigation fell under interstate commerce, New York could not interfere with it, and the law was therefore invalid. In a concurring opinion, Justice William Johnson argued that the national government had exclusive power over interstate commerce, negating state laws interfering with the exercise of that power. Justice Thompson did not participate in the discussion or decision of the case.

Cooley v. Board of Wardens (1852)

Facts of the case A Pennsylvania law required all ships entering or leaving the port of Philadelphia to hire a local pilot. Ships that failed to do so were subject to a fine. Cooley was a ship owner who refused to hire a local pilot and also refused to pay the fine. He argued that the law violated the Commerce Clause, which gives Congress authority over interstate commerce and bars Congress from delegating that authority to the states. This argument was rejected by the lower courts. Question Does a Pennsylvania's law requiring ships to hire a local pilot violate the Commerce Clause of the Constitution? Conclusion The majority held the pilotage law did not violate the Constitution, reasoning localized elements of commerce like selection of pilots could be appropriately delegated to the states. Though navigation was commerce, the Court held that pilotage demanded diverse local rules to cope with varying local conditions. Therefore, Congress's power was selectively exclusive.

Alden v. Maine (1999)

Facts of the case A group of probation officers sued their employer, the State of Maine, in 1992 alleging that the state had violated the overtime provisions of the 1938 Fair Labor Standards Act. Following the Court's decision in Seminole Tribe v. Florida (1996) which held that States are immune from private suits in federal court and that Congress lacks the authority to abrogate that immunity the probation officers' suit was dismissed in Federal district court. Alden and the other probation officers then sued Maine again for violating the Fair Labor Standards Act, this time in state court. The state trial court and the state supreme court both held that Maine had sovereign immunity and could not be sued by private parties in their own court. Question May Congress use its powers under Article I of the Constitution to abrogate a state's sovereign immunity from private suits in its own courts? Conclusion No. A sharply divided court held in a 5-4 decision that Congress may not use its Article I powers to abrogate the states' sovereign immunity. Both the terms and history of the eleventh amendment suggest that States are immune from suits in their own courts. And more generally, the original understanding of the Constitution's structure and the terms of the tenth amendment confirm that states retained much of their sovereignty despite their agreeing that the national government would be supreme when exercising its enumerated powers.

United States v. Lopez (1995)

Facts of the case Alfonzo Lopez, a 12th grade high school student, carried a concealed weapon into his San Antonio, Texas high school. He was charged under Texas law with firearm possession on school premises. The next day, the state charges were dismissed after federal agents charged Lopez with violating a federal criminal statute, the Gun-Free School Zones Act of 1990. The act forbids "any individual knowingly to possess a firearm at a place that [he] knows...is a school zone." Lopez was found guilty following a bench trial and sentenced to six months' imprisonment and two years' supervised release. Question Is the 1990 Gun-Free School Zones Act, forbidding individuals from knowingly carrying a gun in a school zone, unconstitutional because it exceeds the power of Congress to legislate under the Commerce Clause? Conclusion Yes. The possession of a gun in a local school zone is not an economic activity that might, through repetition elsewhere, have a substantial effect on interstate commerce. The law is a criminal statute that has nothing to do with "commerce" or any sort of economic activity.

McCray v. United States (1904)

Facts of the case At the urging of dairy farmers, Congress passed an act imposing a tax of 10 cents per pound on oleomargarine that was artificially colored yellow. Noncolored margarine was taxed only one-quarter of a cent per pound. McCray, a licensed dealer, did not pay the higher tax while selling the colored product. After losing his case in lower courts, McCray appealed to the Supreme Court. Question Did the congressional act overstep the boundaries of the taxing powers established in the Constitution? Conclusion In a 6-to-3 decision, the Court held that the taxes levied on colored and noncolored oleomargarine were constitutional. The Court held that the right of Congress to tax within its delegated powers was essentially "unrestrained," and that "no want of due process of law could possibly result" from exercises of that power. The Court argued that to question the purpose and motive of Congress in exerting its delegated powers would be to "usurp the functions of the legislative in order to control that branch of the government in the performance of its lawful duties."

Complete Auto Transit v. Brady (1977)

Facts of the case Complete Auto Transit was a Michigan corporation doing business in Mississippi. Complete shipped cars into the state where they were distributed for sale. Mississippi imposed a tax on transportation companies for the "privilege of doing business" in the state. The tax was applied equally to businesses involved in intra-and interstate commerce. Question Did the Mississippi tax violate the Commerce Clause because it placed a burden on an activity associated with interstate commerce? Conclusion A unanimous Court found the tax valid. Businesses involved in interstate commerce should assume a just share of the state tax burden. The Court's decision established four criteria to be met for a state tax to be valid and not an unreasonable burden on interstate commerce. The tax must be (1) on an activity connected to the state, (2) fairly apportioned to be based on intrastate commerce, (3) nondiscriminatory, and (4) related to state services provided. These criteria are only valid if Congress has not imposed conflicting regulations.

Michigan v. Long (1983)

Facts of the case David Long was convicted for possession of marijuana found by Michigan police in the passenger compartment and trunk of his car. The police searched the passenger compartment because they suspected Long's vehicle contained weapons potentially dangerous to the officers. After a state appellate court affirmed the conviction, the Michigan Supreme Court reversed. The Michigan Supreme Court held that the search violated the Fourth Amendment and the Michigan Constitution. Question Did the Supreme Court have jurisdiction over state court decisions that rested on "adequate and independent" state grounds? Conclusion The Court, after admitting that it had not developed "a satisfying and consistent approach" regarding lower court references to independent state grounds, held that it had jurisdiction in the case. The Court held that when state court decisions appeared to rest primarily on federal law, it would infer that state courts believed that federal law required them to do so. State courts could expressly state that independent grounds were being used in cases as opposed to constitutional grounds. The Court reasoned that this approach would avoid the rendering of advisory opinions and would decrease the intrusive practice of requiring state courts to clarify decisions to the liking of the Justices. In the case at hand, the Court affirmed the constitutionality of the search and affirmed Long's conviction.

Scott v. Sanford (1857) - Taney's majority opinion

Facts of the case Dred Scott was a slave in Missouri. From 1833 to 1843, he resided in Illinois (a free state) and in the Louisiana Territory, where slavery was forbidden by the Missouri Compromise of 1820. After returning to Missouri, Scott filed suit in Missouri court for his freedom, claiming that his residence in free territory made him a free man. After losing, Scott brought a new suit in federal court. Scott's master maintained that no "negro" or descendant of slaves could be a citizen in the sense of Article III of the Constitution. Question Was Dred Scott free or slave? Conclusion The majority held that "a negro, whose ancestors were imported into [the U.S.], and sold as slaves," whether enslaved or free, could not be an American citizen and therefore did not have standing to sue in federal court. Because the Court lacked jurisdiction, Taney dismissed the case on procedural grounds. Taney further held that the Missouri Compromise of 1820 was unconstitutional and foreclose Congress from freeing slaves within Federal territories. The opinion showed deference to the Missouri courts, which held that moving to a free state did not render Scott emancipated. Finally, Taney ruled that slaves were property under the Fifth Amendment, and that any law that would deprive a slave owner of that property was unconstitutional. In dissent, Benjamin Robbins Curtis criticized Taney for addressing the claim's substance after finding the Court lacked jurisdiction. He pointed out that invalidating the Missouri Compromise was not necessary to resolve the case, and cast doubt on Taney's position that the Founders categorically opposed anti-slavery laws. John McLean echoed Curtis, finding the majority improperly reviewed the claim's substance when its holding should have been limited to procedure. He also argued that men of African descent could be citizens because they already had the right to vote in five states.

Wickard v. Filburn (1942)

Facts of the case Filburn was a small farmer in Ohio who harvested nearly 12 acres of wheat above his allotment under the Agricultural Adjustment Act of 1938. Filburn was penalized under the Act. He argued that the extra wheat that he had produced in violation of the law had been used for his own use and thus had no effect on interstate commerce, since it never had been on the market. In his view, this meant that he had not violated the law because the additional wheat was not subject to regulation under the Commerce Clause. Question Did the Act violate the Commerce Clause? Conclusion A unanimous Court upheld the law. In an opinion authored by Justice Robert Houghwout Jackson, the Court found that the Commerce Clause gives Congress the power to regulate prices in the industry, and this law was rationally related to that legitimate goal. The Court reasoned that Congress could regulate activity within a single state under the Commerce Clause, even if each individual activity had a trivial effect on interstate commerce, as long as the intrastate activity viewed in the aggregate would have a substantial effect on interstate commerce. To this extent, the opinion went against prior decisions that had analyzed whether an activity was local, or whether its effects were direct or indirect.

Proprietors of Charles River Bridge v. Proprietors of Warren Bridge (1837)

Facts of the case In 1785, the Massachusetts legislature incorporated the Charles River Bridge Company to construct a bridge and collect tolls. In 1828, the legislature established the Warren Bridge Company to build a free bridge nearby. Unsurprisingly, the new bridge deprived the old one of traffic and tolls. The Charles River Bridge Company filed suit, claiming the legislature had defaulted on its initial contract. Question Did the legislature enter into an economic contract with the Charles River Bridge Company that was impaired by the second charter in violation of Article I Section 10 of the Constitution? Conclusion In a 5-to-2 decision, the Court held that the state had not entered a contract that prohibited the construction of another bridge on the river at a later date. The Court held that the legislature neither gave exclusive control over the waters of the river nor invaded corporate privilege by interfering with the company's profit-making ability. In balancing the rights of private property against the need for economic development, the Court found that the community interest in creating new channels of travel and trade had priority.

Fletcher v. Peck (1810)

Facts of the case In 1795, the Georgia state legislature passed a land grant awarding territory to four companies. The following year, the legislature voided the law and declared all rights and claims under it to be invalid. In 1800, John Peck acquired land that was part of the original legislative grant. He then sold the land to Robert Fletcher three years later, claiming that the land sales had been legitimate. Fletcher argued that since the original sale of the land had been declared invalid, Peck had no legal right to sell the land and thus committed a breach of contract. Question Could the contract between Fletcher and Peck be invalidated by an act of the Georgia legislature? Conclusion The legislature's repeal of the law was unconstitutional under Article I, Section 10, Clause I (the Contract Clause) of the United States Constitution. The majority concluded the sale between Fletcher and Peck was a binding contract, which under the Contract Clause cannot be invalidated even if it is illegally secured.

Trustees of Dartmouth College v. Woodward (1819)

Facts of the case In 1816, the New Hampshire legislature attempted to change Dartmouth College-- a privately funded institution--into a state university. The legislature changed the school's corporate charter by transferring the control of trustee appointments to the governor. In an attempt to regain authority over the resources of Dartmouth College, the old trustees filed suit against William H. Woodward, who sided with the new appointees. Question Did the New Hampshire legislature unconstitutionally interfere with Dartmouth College's rights under the Contract Clause? Conclusion The Contract Clause (Art 1, Section 10, Clause 1) prohibits states from violating contracts with private or public corporations. In a 6-to-1 decision, the Court concluded that the Contract Clause applies to private as well as public corporations. The Court held that the College's corporate charter qualified as a contract between private parties, with which the legislature could not interfere. The fact that the government had commissioned the charter did not transform the school into a civil institution. Chief Justice Marshall's opinion emphasized that the term "contract" referred to transactions involving individual property rights, not to "the political relations between the government and its citizens."

Stafford v. Wallace (1922)

Facts of the case In 1921, Congress enacted the Packers and Stockyards Act in an attempt to regulate activities of meat packers that were unfair, discriminatory, or deceptive and encouraged the formation of monopolies. Stafford sought an injunction against the enforcement of the Act. After his application was denied, he sought review by the Supreme Court. This case was decided together with Burton v. Clyne. Question Did Congress have authority under the Commerce Clause to pass and enforce the Packers and Stockyards Act of 1921? Conclusion In a 7-to-1 decision, the Court held that the activities controlled by the Act did indeed burden the freedom of commerce and fell within the regulatory jurisdiction of Congress. The Court argued that Congress did not have to wait until after deleterious economic monopolies had developed to regulate particular industries. Drawing on its decision in Swift v. United States, the Court found that business done in the stockyards was an essential part of interstate commerce and thus subject to national legislation.

Home Building and Loan Association v. Blaisdell (1934)

Facts of the case In 1933, Minnesota enacted the Mortgage Moratorium Law in an effort to combat the economic emergency posed by the Great Depression. The law extended the time period in which borrowers could pay back their debts on property to lenders. A court granted an extension to the Blaisdells under this statute while also requiring them to pay $40 a month during the extended period to Home Building and Loan Association, which was the mortgagor of their home. Home argued that the Minnesota law was unconstitutional under the Contracts Clause of the Constitution but was unsuccessful in state courts. Question Did the Minnesota law violate the Contracts Clause? Conclusion In an opinion authored by Justice Charles Hughes, the Court held that the law did not violate the Constitution. The court reasoned that there are limitations on the doctrine embedded in the Contracts Clause (Section 10 of Article I). There may be a public need to restrain private rights to further the public interest when there is an emergency. The Framers of the Constitution could not have foreseen all possible modern problems, so the Constitution should not be interpreted in too rigid a way to allow for responding to them. This statute met the relevant five-factor test because there was a genuine emergency, the legislation was designed to help the public in general, the relief was narrowly tailored to the problem, the mortgagor's interests were not seriously undermined, and the legislation is temporary. Since the demands of the Great Depression were vital to all of the state's citizens, the Court held the law was a legitimate use of Minnesota's police power. Justice Sutherland dissented, joined by Justices Van Devanter, McReynolds, and Butler.

South Dakota v. Dole (1987)

Facts of the case In 1984, Congress enacted legislation ordering the Secretary of Transportation to withhold five percent of federal highway funds from states that did not adopt a 21-year-old minimum drinking age. South Dakota, a state that permitted persons 19 years of age to purchase alcohol, challenged the law. Question Did Congress exceed its spending powers, or violate the Twenty-first Amendment, by passing legislation conditioning the award of federal highway funds on the states' adoption of a uniform minimum drinking age? Conclusion No. In a 7-to-2 decision, the Court held that Congress, acting indirectly to encourage uniformity in states' drinking ages, was within constitutional bounds. The Court found that the legislation was in pursuit of "the general welfare," and that the means chosen to do so were reasonable. The Court also held that the Twenty-first Amendment's limitations on spending power were not prohibitions on congressional attempts to achieve federal objectives indirectly. The five percent loss of highway funds was not unduly coercive.

Lucas v. South Carolina Coastal Council (1992)

Facts of the case In 1986, Lucas bought two residential lots on the Isle of Palms, a South Carolina barrier island. He intended to build single-family homes as on the adjacent lots. In 1988, the state legislature enacted a law which barred Lucas from erecting permanent habitable structures on his land. The law aimed to protect erosion and destruction of barrier islands. Lucas sued and won a large monetary judgment. The state appealed. Question Does the construction ban depriving Lucas of all economically viable use of his property amount to a "taking" calling for "just compensation" under the Fifth and Fourteenth Amendments? Conclusion Yes. In a 6-to-2 decision, the Court relied on the trial court's finding that Lucas's lots had been rendered valueless by the state law. "[W]hen the owner of real property has been called upon to sacrifice all economically beneficial uses in the name of the common good...he has suffered a taking."

United States v. Morrison (2000)

Facts of the case In 1994, while enrolled at Virginia Polytechnic Institute (Virginia Tech), Christy Brzonkala alleged that Antonio Morrison and James Crawford, both students and varsity football players at Virginia Tech, raped her. In 1995, Brzonkala filed a complaint against Morrison and Crawford under Virginia Tech's Sexual Assault Policy. After a hearing, Morrison was found guilty of sexual assault and sentenced to immediate suspension for two semesters. Crawford was not punished. A second hearing again found Morrison guilty. After an appeal through the university's administrative system, Morrison's punishment was set aside, as it was found to be "excessive." Ultimately, Brzonkala dropped out of the university. Brzonkala then sued Morrison, Crawford, and Virginia Tech in Federal District Court, alleging that Morrison's and Crawford's attack violated 42 USC section 13981, part of the Violence Against Women Act of 1994 (VAWA), which provides a federal civil remedy for the victims of gender-motivated violence. Morrison and Crawford moved to dismiss Brzonkala's suit on the ground that section 13981's civil remedy was unconstitutional. In dismissing the complaint, the District Court found that that Congress lacked authority to enact section 13981 under either the Commerce Clause or the Fourteenth Amendment, which Congress had explicitly identified as the sources of federal authority for it. Ultimately, the Court of Appeals affirmed. Question Does Congress have the authority to enact the Violence Against Women Act of 1994 under either the Commerce Clause or Fourteenth Amendment? Conclusion No. In a 5-4 opinion delivered by Chief Justice William H. Rehnquist, the Court held that Congress lacked the authority to enact a statute under the Commerce Clause or the Fourteenth Amendment since the statute did not regulate an activity that substantially affected interstate commerce nor did it redress harm caused by the state. Chief Justice Rehnquist wrote for the Court that [i]f the allegations here are true, no civilized system of justice could fail to provide [Brzonkala] a remedy for the conduct of...Morrison. But under our federal system that remedy must be provided by the Commonwealth of Virginia, and not by the United States." Dissenting, Justice Stephen G. Breyer argued that the majority opinion "illustrates the difficulty of finding a workable judicial Commerce Clause touchstone." Additionally, Justice David H. Souter, dissenting, noted that VAWA contained a "mountain of data assembled by Congress...showing the effects of violence against women on interstate commerce."

Gonzales v. Raich (2005)

Facts of the case In 1996 California voters passed the Compassionate Use Act, legalizing marijuana for medical use. California's law conflicted with the federal Controlled Substances Act (CSA), which banned possession of marijuana. After the Drug Enforcement Administration (DEA) seized doctor-prescribed marijuana from a patient's home, a group of medical marijuana users sued the DEA and U.S. Attorney General John Ashcroft in federal district court. The medical marijuana users argued the Controlled Substances Act - which Congress passed using its constitutional power to regulate interstate commerce - exceeded Congress' commerce clause power. The district court ruled against the group. The Ninth Circuit Court of Appeals reversed and ruled the CSA unconstitutional as it applied to intrastate (within a state) medical marijuana use. Relying on two U.S. Supreme Court decisions that narrowed Congress' commerce clause power - U.S. v. Lopez (1995) and U.S. v. Morrison (2000) - the Ninth Circuit ruled using medical marijuana did not "substantially affect" interstate commerce and therefore could not be regulated by Congress. Question Does the Controlled Substances Act (21 U.S.C. 801) exceed Congress' power under the commerce clause as applied to the intrastate cultivation and possession of marijuana for medical use? Conclusion No. In a 6-3 opinion delivered by Justice John Paul Stevens, the Court held that the commerce clause gave Congress authority to prohibit the local cultivation and use of marijuana, despite state law to the contrary. Stevens argued that the Court's precedent "firmly established" Congress' commerce clause power to regulate purely local activities that are part of a "class of activities" with a substantial effect on interstate commerce. The majority argued that Congress could ban local marijuana use because it was part of such a "class of activities": the national marijuana market. Local use affected supply and demand in the national marijuana market, making the regulation of intrastate use "essential" to regulating the drug's national market. The majority distinguished the case from Lopez and Morrison. In those cases, statutes regulated non-economic activity and fell entirely outside Congress' commerce power; in this case, the Court was asked to strike down a particular application of a valid statutory scheme.

Maine v. Taylor (1986)

Facts of the case In order to protect its fisheries from parasites and non-native species, the state of Maine prohibited the importation of live baitfish. Robert J. Taylor, the owner of a bait business, violated the law and was prosecuted by Maine authorities. Question Did the Maine law unconstitutionally burden interstate commerce, violating the Commerce Clause? Conclusion No. In an 8-to-1 decision, the Court held that the limitation imposed by the Commerce Clause on state regulatory power was not absolute and that the States "retain[ed] authority under their general police powers to regulate matters of 'legitimate local concern.'" The Court found that Maine's ban on the importation oflive baitfish served a legitimate local purpose that could not adequately be served by available nondiscriminatory alternatives. The Court argued that the ban was not a simple case of "arbitrary discrimination against interstate commerce."

United States Trust Co. v. New Jersey (1977)

Facts of the case New York and New Jersey had established a Port Authority to enhance water-bound business between the two states. In 1974, the states repealed a 1962 bond agreement which limited the Authority to administer commercial and passenger railroad subsidies. Question In repealing the 1962 agreement, did the states violate the Contract Clause? Conclusion The repeal violated the Constitution. Justice Blackmun argued that the states could have implemented a less drastic solution to encourage people to use commuter train services in lieu of driving their cars. (State leaders thought the increase in bridge fares that would occur with the agreement's repeal would cause this to occur.) Furthermore, since the need to facilitate mass transportation in the New York metropolitan area had been a concern long before 1962, the states could not justify their action as a response to unforeseen circumstances.

Printz v. United States (1997)

Facts of the case The Brady Handgun Violence Prevention Act (Brady Bill) required "local chief law enforcement officers" (CLEOs) to perform background-checks on prospective handgun purchasers, until such time as the Attorney General establishes a federal system for this purpose. County sheriffs Jay Printz and Richard Mack, separately challenged the constitutionality of this interim provision of the Brady Bill on behalf of CLEOs in Montana and Arizona respectively. In both cases District Courts found the background-checks unconstitutional, but ruled that since this requirement was severable from the rest of the Brady Bill a voluntary background-check system could remain. On appeal from the Ninth Circuit's ruling that the interim background-check provisions were constitutional, the Supreme Court granted certiorari and consolidated the two cases deciding this one along with Mack v. United States. Question Using the Necessary and Proper Clause of Article I as justification, can Congress temporarily require state CLEOs to regulate handgun purchases by performing those duties called for by the Brady Bill's handgun applicant background-checks? Conclusion No. The Court constructed its opinion on the old principle that state legislatures are not subject to federal direction. The Court explained that while Congress may require the federal government to regulate commerce directly, in this case by performing background-checks on applicants for handgun ownership, the Necessary and Proper Clause does not empower it to compel state CLEOs to fulfill its federal tasks for it - even temporarily. The Court added that the Brady Bill could not require CLEOs to perform the related tasks of disposing of handgun-application forms or notifying certain applicants of the reasons for their refusal in writing, since the Brady Bill reserved such duties only for those CLEO's who voluntarily accepted them.

New York v. United States (1992)

Facts of the case The Low-Level Radioactive Waste Management Act Amendments of 1985 required states alone or in compacts with other states to dispose of such radioactive waste within their borders. New York State and Allegany and Cortland counties were frustrated in their compliance efforts by resistance from residents to proposed radioactive waste sites and a lack of cooperation from neighboring states. New York filed suit against the federal government, questioning the authority of Congress to regulate state waste management. Question Does the Low-Level Waste Act violate the Tenth Amendment and the "guarantee clause" of Article Four? Conclusion In a 6-3 decision, the Court upheld two of the three provisions of the Act under review, reasoning that Congress had the authority under the Commerce Clause to use financial rewards and access to disposal sites as incentives for state waste management. The third provision, the "take-title" qualification, stipulated that states must take legal ownership and liability for low-level waste or by the regulatory act. "Either type of federal action," wrote Justice Sandra Day O'Connor, "would 'commandeer' state governments into the service of federal regulatory purposes, and would for this reason be inconsistent with the Constitution's division of authority between federal and state governments." This last provision violated the Tenth Amendment.

Michelin Tire Corp. v. Wages (1976)

Facts of the case The Michelin Tire Corporation (MTC) operated a warehouse in Gwinnett County, Georgia, in which products imported from France and Nova Scotia were stored for later distribution. The County levied a nondiscriminatory ad valorem property tax on the goods (a percent of the property's value). MTC claimed that the contents of the warehouse were constitutionally free from state taxation because they were in their original containers. The county declared that the products were subject to the tax because they had been sorted and arranged for sale. Question Did the Gwinnett County tax violate the Import-Export Clause by taxing goods that maintained the character of imports? Conclusion The Court affirmed the decision of the Georgia Supreme Court, finding the tax to be valid. The Court stated that the Framers of the Constitution had adopted the Import-Export Clause to give the federal government a source of revenue and the superior position to regulate such foreign trade. This was to overcome the problems under the Articles of Confederation where states lacked uniformity in import regulation, burdening inter-state trade. The property tax was consistent with the Import-Export Clause because it did not (1) interfere with the Federal Government's regulation of foreign commerce (2) deprive the Federal Government of its exclusive right to revenues from imposts and duties on imports (3) interfere with the free flow of goods between the states. It taxed the use of the property and was not based on the origin of the goods.

Quill Corp. v. North Dakota (1992)

Facts of the case Through its Tax Commissioner, the state of North Dakota filed an action in state court to force the Quill Corporation, an out-of-state mail-order office equipment retailer, to charge a North Dakota use tax on Quill merchandise to be used within the state. The state court ruled in favor of Quill, grounding its decision on Bellas Hess, Inc. v. Department of Revenue of Illinois, 386 U.S. 753. In this 1967 case, the United States Supreme Court found a similar Illinois statute to be in violation of both the Due Process Clause of the Fourteenth Amendment and the Commerce Clause of the United States Constitution. The North Dakota Supreme Court reversed, basing its decision on a rejection of Bellas Hess in light of the "tremendous social, economic, commercial, and legal innovations" since it had been decided. Question 1) Had Bellas Hess become obsolete? 2) Was North Dakota's imposition of a use tax upon the merchandise of the Quill Corporation in compliance with the Due Process Clause and the Commerce Clause? Conclusion No and No. In a majority opinion authored by Justice John Paul Stevens, the Court admitted that, over time, subsequent cases have allowed for more flexibility than Bellas Hess. Nevertheless, the Court maintained that this evolution does not suggest a rejection of Bellas Hess. The Court also determined that North Dakota's imposition of the use tax did not constitute a breach of the Due Process Clause because the Quill Corporation had sufficient contact with the state's residents and benefited from the state's tax revenue. However, it found the use tax to be unconstitutional because it interfered with interstate commerce, rendering it a violation of the Commerce Clause. Consequently, the Court reversed the North Dakota Supreme Court's decision by ruling in favor of the Quill Corporation.

Heart of Atlanta Motel v. United States (1964)

Facts of the case Title II of the Civil Rights Act of 1964 forbade racial discrimination by places of public accommodation if their operations affected commerce. The Heart of Atlanta Motel in Atlanta, Georgia, refused to accept Black Americans. The government sought to enjoin the motel from discriminating on the basis of race under Title II. Question Did Congress, in passing Title II of the 1964 Civil Rights Act, exceed its Commerce Clause powers by depriving places of public accommodation of the right to choose their own customers? Conclusion The Commerce Clause extends the anti-discrimination provisions in the Civil Rights Act of 1964 to hotels that host travelers from outside the state. In a unanimous decision authored by Justice Clark, the Court held the government could enjoin the motel from discriminating on the basis of race under the Commerce Clause. Since the motel was positioned near Interstates 75 and 85 and received most of its business from outside Georgia, this showed that it had an impact on interstate commerce, which is all that is needed to justify Congress in exercising the Commerce Clause power. Justices Black, Douglas, and Goldberg concurred in a separate opinion.

National Labor Relations Board v. Jones & Laughlin Steel Corporation (1937)

Facts of the case With the National Labor Relations Act (NLRA) of 1935, Congress determined that labor-management disputes were directly related to the flow of interstate commerce and, thus, could be regulated by the national government. The National Labor Relations Board (NLRB) charged Jones & Laughlin Steel Co. the country's fourth largest steel producer, with discriminating against employees who were union members. Question Was the NLRA consistent with the Commerce Clause? Conclusion In an opinion written by Chief Justice Charles Evans Hughes, the majority found that companies cannot discriminate against employees for exercising their fundamental right to unionize. The Court upheld the Act, reasoning that it was narrowly constructed so as to regulate industrial activities which had the potential to restrict interstate commerce. The majority stated that any significant effect (direct or indirect) on interstate commerce allows Congress to regulate an activity under the Commerce Clause. While the manufacturing process or relationships between labor and management may not have a direct impact on the flow of goods, they have an aggregate impact on commerce. In this case, the potential secession of manufacturing activity due to conflicts between management and labor could potentially impede interstate commerce. However, Hughes carefully limited the opinion to exclude situations in which an activity had such an inconsequential or remote impact on interstate commerce that it exclusively impacted local matters.