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Keywords

contractplaintiffdefendantstatuteinjunction
contractplaintiffdefendantstatute

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Henneford v. Silas Mason Co., 300 U.S. 577, 57 S.Ct. 524, 81 L.Ed. 814

Facts

The plaintiffs, contractors working on the Grand Coulee Dam, brought machinery and materials into Washington that they had purchased in other states. The Washington Tax Commission assessed a use tax on these items, which amounted to $18,423.78. The plaintiffs argued that this tax violated the commerce clause since it applied to items purchased out of state. The District Court ruled in favor of the plaintiffs, declaring the tax void and granting an injunction against its enforcement.

The plaintiffs, contractors working on the Grand Coulee Dam, brought machinery and materials into Washington that they had purchased in other states.

Issue

Does the Washington state use tax on chattels purchased out of state violate the commerce clause of the U.S. Constitution?

Does the Washington state use tax on chattels purchased out of state violate the commerce clause of the U.S. Constitution?

Rule

A state may impose a nondiscriminatory tax on the use of property that has become part of the common mass of property within the state, provided it does not discriminate against interstate commerce.

A state may impose a nondiscriminatory tax on the use of property that has become part of the common mass of property within the state, provided it does not discriminate against interstate commerce.

Analysis

The court analyzed the Washington statute and determined that the use tax was not discriminatory against interstate commerce. It found that the tax was applied equally to all users of property, regardless of where the property was purchased, and that it did not impose a burden on interstate commerce since it was levied after the property had ceased to be in transit.

The court analyzed the Washington statute and determined that the use tax was not discriminatory against interstate commerce.

Conclusion

The court reversed the District Court's decision, holding that the Washington use tax was valid and did not violate the commerce clause.

The court reversed the District Court's decision, holding that the Washington use tax was valid and did not violate the commerce clause.

Who won?

The defendants, the Tax Commission of Washington, prevailed in the case because the court found that the use tax did not violate the commerce clause and was applied uniformly.

The defendants, the Tax Commission of Washington, prevailed in the case because the court found that the use tax did not violate the commerce clause and was applied uniformly.

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