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Maryland v. Louisiana | |
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Argued January 19, 1981 Decided May 26, 1981 | |
Full case name | Maryland v. Louisiana |
Citations | 451 U.S. 725 ( more ) |
Argument | Oral argument |
Holding | |
Louisiana's exceptions to the Special Master's recommendation that the motion to dismiss be denied are rejected. | |
Court membership | |
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Case opinions | |
Majority | White, joined by Burger, Brennan, Stewart, Marshall, Blackmun, Stevens |
Concurrence | Burger |
Dissent | Rehnquist |
Powell took no part in the consideration or decision of the case. |
Maryland v. Louisiana, 451 U.S. 725 (1981), is a Supreme Court case in which Maryland challenged a Louisiana law that forbid any tax on natural gas that would be extracted within the state. Maryland argued that it broke the Commerce Clause. The court would rule in the favor of Maryland. [1]
Hearing:
Many different entities including the United States, the Federal Energy Regulatory Commission, several states including Maryland, and multiple gas pipeline companies all went against Louisiana's tax constitutionality. They declared that the tax should not be able allocate the tax to other consumers, but only to the ultimate consumer. In the case's hearing of evidence, it is said that Louisiana's purpose of the tax was to pay back the citizens of Louisiana who were affected by the damages to the state's coastal regions, as well as compensating citizens for the costs that the state payed to protect those resources... [2]
Decision:
The U.S. Supreme Court would favor Maryland in a 7-1 ruling. The favor ruled that Louisiana unconstitutionally used its "first-use" tax on natural gases and violated the Commerce Clause of the United States Constitution which says that Congress has the power to regulate commerce with foreign nations, several states, and even Indian Tribes.
This clause was first designed to stop individual states from making laws that can unfairly restrict or hurt trade between states. This helps with keeping the market open and fair for the U.S.
Aftermath:
Post ruling of the court, Louisiana had to stop its "first-use" tax, and it caused the Supremacy Clause from the Constitution to be reinforced as an example for the future. The court said the Natural Gas Act was violated by the taxing that took place and affirmed the Supremacy Clauses status with that decision.
Article Six of the United States Constitution establishes the laws and treaties of the United States made in accordance with it as the supreme law of the land, forbids a religious test as a requirement for holding a governmental position, and holds the United States under the Constitution responsible for debts incurred by the United States under the Articles of Confederation.
McCulloch v. Maryland, 17 U.S. 316 (1819), was a landmark U.S. Supreme Court decision that defined the scope of the U.S. Congress's legislative power and how it relates to the powers of American state legislatures. The dispute in McCulloch involved the legality of the national bank and a tax that the state of Maryland imposed on it. In its ruling, the Supreme Court established firstly that the "Necessary and Proper" Clause of the U.S. Constitution gives the U.S. federal government certain implied powers necessary and proper for the exercise of the powers enumerated explicitly in the Constitution, and secondly that the American federal government is supreme over the states, and so states' ability to interfere with the federal government is restricted. Since the legislature has the authority to tax and spend, the court held that it therefore has authority to establish a national bank, as being "necessary and proper" to that end.
The Dormant Commerce Clause, or Negative Commerce Clause, in American constitutional law, is a legal doctrine that courts in the United States have inferred from the Commerce Clause in Article I of the US Constitution. The primary focus of the doctrine is barring state protectionism. The Dormant Commerce Clause is used to prohibit state legislation that discriminates against, or unduly burdens, interstate or international commerce. Courts first determine whether a state regulation discriminates on its face against interstate commerce or whether it has the purpose or effect of discriminating against interstate commerce. If the statute is discriminatory, the state has the burden to justify both the local benefits flowing from the statute and to show the state has no other means of advancing the legitimate local purpose.
Smith v. Turner; Norris v. Boston, 48 U.S. 283 (1849), were two similar cases, argued together before the United States Supreme Court, which decided 5–4 that states do not have the right to impose a tax that is determined by the number of passengers of a designated category on board a ship and/or disembarking into the State. The cases are sometimes called the Passenger Case or Passenger Cases.
Canton Railroad Company v. Rogan, 340 U.S. 511 (1951), is a case in which the United States Supreme Court held that a state franchise tax upon the services performed by a railroad in handling imported and exported goods did not violate the Import-Export Clause of the United States Constitution.
Garcia v. San Antonio Metropolitan Transit Authority, 469 U.S. 528 (1985), is a landmark United States Supreme Court decision in which the Court held that the Congress has the power under the Commerce Clause of the Constitution to extend the Fair Labor Standards Act, which requires that employers provide minimum wage and overtime pay to their employees, to state and local governments. In this case, the Court overruled its previous decision in National League of Cities v. Usery, in which the Court had held that regulation of the activities of state and local governments "in areas of traditional governmental functions" would violate the Tenth Amendment to the United States Constitution.
Complete Auto Transit, Inc. v. Brady, 430 U.S. 274 (1977), is a United States Supreme Court case regarding the Commerce Clause and sales tax.
In the law of the United States, federal preemption is the invalidation of a U.S. state law that conflicts with federal law.
Commonwealth Edison Co. v. Montana, 453 U.S. 609 (1981), is a 6-to-3 ruling by the Supreme Court of the United States that held that a severance tax in Montana does not violate the Commerce Clause or the Supremacy Clause of the United States Constitution.
Exxon Corp. v. Governor of Maryland, 437 U.S. 117 (1978), was a case in which the Supreme Court of the United States upheld a Maryland law prohibiting oil producers and refiners from operating service stations within its borders. The challengers, including Exxon, claimed that the law violated the Dormant Commerce Clause. Justice Stevens wrote for the majority, which disagreed with Exxon et al.: "Since Maryland's entire gasoline supply flows in interstate commerce and since there are no local producers or refiners, such claims of disparate treatment between interstate and local commerce would be meritless." Exxon challenged the Maryland statute in Circuit Court which ruled the statute invalid. The Maryland Court of Appeals reversed the ruling.
Arizona Public Service Co. v. Snead, 441 U.S. 141 (1979), was a United States Supreme Court case in which the Court held that a New Mexico tax on the generation of electricity was invalid under the Supremacy Clause of the United States Constitution. Snead was the director of the New Mexico Taxation and Revenue Department.
The Supremacy Clause of the Constitution of the United States establishes that the Constitution, federal laws made pursuant to it, and treaties made under its authority, constitute the "supreme Law of the Land", and thus take priority over any conflicting state laws. It provides that state courts are bound by, and state constitutions subordinate to, the supreme law. However, federal statutes and treaties must be within the parameters of the Constitution; that is, they must be pursuant to the federal government's enumerated powers, and not violate other constitutional limits on federal power, such as the Bill of Rights—of particular interest is the Tenth Amendment to the United States Constitution, which states that the federal government has only those powers that are delegated to it by the Constitution. It is the responsibility of the United States Supreme Court in that case to exercise the power of judicial review: the ability to invalidate a statute for violating a provision of the Constitution.
United Gas Pipe Line Co. v. Ideal Cement Co., 369 U.S. 134 (1962), is a United States Supreme Court case which vacated a lower appellate court decision, holding that federal courts should abstain from ruling on the constitutionality of a state tax issue that state courts should determine.
Comptroller of the Treasury of Maryland v. Wynne, 575 U.S. 542 (2015), is a 2015 U.S. Supreme Court decision that applied the Dormant Commerce Clause doctrine to Maryland's personal income tax scheme and found that the failure to provide a full credit for income taxes paid to other states was unconstitutional.
Article I, § 10, clause 2 of the United States Constitution, known as the Import-Export Clause, prevents the states, without the consent of Congress, from imposing tariffs on imports and exports above what is necessary for their inspection laws and secures for the federal government the revenues from all tariffs on imports and exports. Several nineteenth century Supreme Court cases applied this clause to duties and imposts on interstate imports and exports. In 1869, the United States Supreme Court ruled that the Import-Export Clause only applied to imports and exports with foreign nations and did not apply to imports and exports with other states, although this interpretation has been questioned by modern legal scholars.
Brown v. Maryland, 25 U.S. 419 (1827), was a significant United States Supreme Court case which interpreted the Import-Export and Commerce Clauses of the U.S. Constitution to prohibit discriminatory taxation by states against imported items after importation, rather than only at the time of importation. The state of Maryland passed a law requiring importers of foreign goods to obtain a license for selling their products. Brown was charged under this law and appealed. It was the first case in which the U.S. Supreme Court construed the Import-Export Clause. Chief Justice John Marshall delivered the opinion of the court, ruling that Maryland's statute violated the Import-Export and Commerce Clauses and the federal law was supreme. He alleged that the power of a state to tax goods did not apply if they remained in their "original package". A license tax on the importer was essentially the same as a tax on an import itself. Despite arguing the case for Maryland, future chief justice Roger Taney admitted that the case was correctly decided.
Pacific States Telephone & Telegraph Co. v. Oregon, 223 U.S. 118 (1912), was a decision of the Supreme Court of the United States involving the constitutionality of the citizens' initiative and the enforceability of the Guarantee Clause of the Constitution. In an opinion authored by Chief Justice Edward Douglass White, a unanimous Court rejected a corporation's argument that the Guarantee Clause forbade Oregon's initiative process, citing Luther v. Borden to conclude that such claims presented political questions and thus were non-justiciable.
Text of Maryland v. Louisiana, 451 U.S. 725(1981) is available from: Justia Library of Congress Oyez (oral argument audio)