Brown v. Maryland
"Brown v. Maryland" is a landmark Supreme Court case that addressed the constitutionality of a Maryland law requiring importers of foreign goods to obtain a license for taxation. The state argued that this licensing requirement was distinct from taxing the goods themselves. However, the Supreme Court, led by Chief Justice John Marshall, ruled by a 6-1 majority that the law was unconstitutional. The Court established the original packaging rule, which stated that as long as imported goods remained in their original packaging, they were protected from state taxation under both the imports-exports clause and the commerce clause. This decision underscored the principle that federal authority over interstate commerce takes precedence over state taxation, although the ruling did allow for state taxes once the goods became mixed with local property. Over time, the implications of this ruling evolved, particularly with the 1976 decision in Michelin Tire Corp. v. Wages, which allowed states to impose property taxes on foreign imports stored within their jurisdiction. Overall, "Brown v. Maryland" played a crucial role in shaping the balance of power between state and federal governments regarding commerce and taxation.
Brown v. Maryland
Date: March 12, 1827
Citation: 12 Wheat. (25 U.S.) 419
Issue: State taxes
Significance: The Supreme Court held that a state tax on imported goods that were still in the original packaging and not mixed with other goods violated both the imports-exports and the commerce clause.
A Maryland statute required importers of foreign goods to purchase a license. The state claimed that a license tax on the importer was different from a tax on the import itself. By a 6-1 vote, the Supreme Court struck down the law. Chief Justice John Marshallenunciated the original packaging rule, which said that as long as imported goods were in the original packaging, a state tax was an unconstitutional violation of both the imports-exports and the commerce clause. Once imported goods became mixed up with other property, the state could tax them. This ruling enhanced federal powers without permanently insulating imported goods from state taxation.
In 1869 the Court decided that the original packaging rule did not apply to goods moving in interstate commerce. In Michelin Tire Corp. v. Wages (1976), the Court almost entirely abandoned the rule when it allowed states to assess nondiscriminatory property taxes on foreign imports in storage.