Featured Chrome Extensions:

Casey IRACs are produced by an AI that analyzes the opinion’s content to construct its analysis. While we strive for accuracy, the output may not be flawless. For a complete and precise understanding, please refer to the linked opinions above.

Keywords

contractdue processappellant
jurisdictionstatutetrialdue processsustainedappellant

Related Cases

Schroeder v. City of New York, 371 U.S. 208, 83 S.Ct. 279, 9 L.Ed.2d 255, 89 A.L.R.2d 1398
View Case »
J.C. Penney Co., Inc. v. Olsen, 796 S.W.2d 943
View Case »
Virginia Indonesia Co. v. Harris County Appraisal Dist., 910 S.W.2d 905, 39 Tex. Sup. Ct. J. 37
View Case »
Yale Club of Chicago v. Department of Revenue, 214 Ill.App.3d 468, 574 N.E.2d 31, 158 Ill.Dec. 237, 68 Ed. Law Rep. 458
View Case »
Columbus Bd. of Edn. v. Tracy, 73 Ohio St.3d 75, 652 N.E.2d 661, 1995 -Ohio- 213
View Case »
Justia Law Link
LexisNexis Link
Westlaw Link
CourtListener Link
Oyez Link

Standard Pressed Steel Co. v. Washington Dept. of Revenue, 419 U.S. 560, 95 S.Ct. 706, 42 L.Ed.2d 719

Facts

The appellant manufacturer, with its home office in Pennsylvania and a manufacturing plant in California, sold aerospace fasteners primarily to Boeing in Washington. It had one employee in Washington, an engineer named Martinson, who consulted with Boeing about its fastener needs and followed up on any issues after delivery. The state taxing authorities determined that Martinson's activities were sufficient to justify the imposition of the business and occupation tax on the manufacturer's gross receipts from sales to Boeing.

Appellant, a manufacturer of industrial and aerospace fasteners (nuts and bolts generally), has its home office in Pennsylvania, one manufacturing plant there and another in California. Its principal customer in the State of Washington is the Boeing Company, in Seattle.

Issue

Whether the imposition of Washington State's business and occupation tax on the manufacturer's gross receipts from sales to a Washington aerospace company violates due process or the commerce clause.

Whether the imposition of the tax violates due process because the in-state activities were so thin and inconsequential as to make the tax on activities occurring beyond the borders of the State one which has no reasonable relation to the protection and benefits conferred by the taxing State.

Rule

The imposition of a tax does not violate due process if it bears a relationship to the benefits conferred by the state, and it does not violate the commerce clause if there is no showing of multiple taxation on interstate business and the tax is apportioned to intrastate activities.

There is no violation of due as the measure of the tax bears a relationship to the benefits conferred on appellant by the State.

Analysis

The court found that the activities of the manufacturer's employee in Washington were substantial enough to justify the tax, as they contributed to maintaining valuable contractual relations with Boeing. The court noted that the manufacturer did not demonstrate any risk of multiple taxation and that the tax was appropriately apportioned to the activities conducted within the state.

The Board sustained the assessment of the Washington business and occupation tax, Wash.Rev.Code s 82.04.270 (1972), levied on the unapportioned gross receipts of appellant resulting from its sale of fasteners to Boeing.

Conclusion

The Supreme Court affirmed the decision of the lower courts, holding that Washington's business and occupation tax on the manufacturer was constitutional.

Held: Washington's business and occupation tax on appellant is constitutional.

Who won?

Washington State prevailed in the case because the court found that the tax was constitutionally applied based on the manufacturer's activities within the state.

The constitutionality, as applied, of the Washington statute being challenged, we noted probable jurisdiction, 417 U.S. 966, 94 S.Ct. 3169, 41 L.Ed.2d 1138 (1974).

You must be