United States Express Co. v. Minnesota, 223 U.S. 335 (1912)

United States Express Co. v. Minnesota

No. 708

Argued January 16, 17, 1912
Decided February 19, 1912
223 U.S. 335

ERROR TO THE SUPREME COURT

OF THE STATE OF MINNESOTA

Syllabus

In determining whether a state tax on earnings is constitutional, this Court is bound by the decision of the state court as to what classes of earnings are included in estimating the earnings to be taxed.

A state may tax property within the state although it is used in interstate commerce.

A state may not burden interstate commerce by taxing its commerce, but it may measure the value of property of a corporation engaged in interstate commerce within the state by the gross receipts, and impose a tax thereon if the same is in lieu of all taxes upon the property of such corporation. Oklahoma v. Wells, Fargo & Co., ante, p. 298, distinguished.

It is difficult at times, to draw the line between state taxes that are unconstitutional as burdening interstate commerce and a legitimate property tax measured in part by income from interstate commerce. While the determination by the state court that a tax so measured is a property tax is not binding on this Court, in this case, this Court will not say that the conclusion is not well founded.

The Minnesota statutes, Revised Laws, 1905, Chapter 11, taxing express companies on their property employed within the state six percent of the gross receipts in lieu of all other taxes is an exercise in good faith of legitimate taxing power, and is not an unconstitutional burden upon interstate commerce.

The facts, which involve the constitutionality of a statute of the State of Minnesota taxing express companies, are stated in the opinion.