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Keywords

regulationsustained
plaintiffstatuteregulation

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Dozier v. State of Alabama, 218 U.S. 124, 30 S.Ct. 649, 54 L.Ed. 965, 28 L.R.A.N.S. 264

Facts

The Chicago Crayon Company, based in Chicago, was engaged in making and enlarging portraits and manufacturing picture frames. They solicited orders in Alabama without paying the required license tax. The orders included a provision for frames at factory prices, and the company’s agent in Alabama delivered the pictures and frames. The Alabama Supreme Court sustained the conviction, asserting that the sale of frames was a local transaction.

The plaintiff in error was convicted and sentenced to a fine on a complaint for breach of an Alabama statute of March 7, 1907. By § 17 of that act a license tax was imposed on persons who did not have a permanent place of business in the state, and also keep picture frames as a part of their stock in trade, if they solicited orders for the enlargement of photographs or pictures of any character, or for picture frames, whether they made charge for such frames or not, or if they sold or disposed of picture frames.

Issue

Whether the sale of picture frames by the Chicago Crayon Company, which was conducted without a license in Alabama, constituted a violation of state law or was protected under interstate commerce.

No doubt it is true that the customer was not bound to take the frame unless he saw fit, and that the sale of it took place wholly within the state of Alabama, if a sale was made.

Rule

The court applied the principle that transactions involving interstate commerce cannot be regulated by state law if they are integral to the interstate transaction.

Under the decisions, the statute, as applied to this case, is a regulation of commerce among the states, and void under the Constitution of the United States. Art. 1, § 8.

Analysis

The U.S. Supreme Court analyzed the nature of the transaction, concluding that the sale of frames was not a separate local sale but rather part of a continuous interstate transaction. The frames were sent from Chicago along with the pictures, and the pricing was part of the interstate agreement. Therefore, the court determined that the state’s license tax could not be applied to this transaction.

It was agreed that the frame should be offered along with the picture. The offer was a part of the interstate bargain, and as it was agreed that the frame should be offered ‘at factory prices,’ and the company and factory were in Chicago, obviously it was contemplated, if not agreed, that the frame should come on with the picture.

Conclusion

The U.S. Supreme Court reversed the judgment of the Alabama Supreme Court, ruling that the state could not impose a license tax on the sale of frames as it was part of interstate commerce.

Judgment reversed.

Who won?

The Chicago Crayon Company prevailed in the case because the U.S. Supreme Court found that the sale of frames was part of interstate commerce and thus exempt from state regulation.

The U.S. Supreme Court analyzed the nature of the transaction, concluding that the sale of frames was not a separate local sale but rather part of a continuous interstate transaction.

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