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State of Minnesota v. Blasius, 290 U.S. 1, 54 S.Ct. 34, 78 L.Ed. 131

Facts

George Blasius owned eleven head of cattle at the St. Paul Union Stockyards, which were assessed for taxation as his personal property. He contended that the cattle were part of interstate commerce and therefore exempt from state taxation. The cattle had been consigned for sale at the stockyards and were sold to a nonresident purchaser shortly after the tax date. The court found that the cattle were not in transit but had come to rest in Minnesota, where they were held for sale.

George Blasius owned eleven head of cattle at the St. Paul Union Stockyards, which were assessed for taxation as his personal property. He contended that the cattle were part of interstate commerce and therefore exempt from state taxation. The cattle had been consigned for sale at the stockyards and were sold to a nonresident purchaser shortly after the tax date. The court found that the cattle were not in transit but had come to rest in Minnesota, where they were held for sale.

Issue

Whether the cattle owned by Blasius were subject to state taxation given his claim that they were in interstate commerce.

Whether the cattle owned by Blasius were subject to state taxation given his claim that they were in interstate commerce.

Rule

A state may impose a nondiscriminatory tax on property that has come to rest within its borders, even if that property is connected to interstate commerce, provided there is no conflict with federal authority.

A state may impose a nondiscriminatory tax on property that has come to rest within its borders, even if that property is connected to interstate commerce, provided there is no conflict with federal authority.

Analysis

The court determined that the cattle had ceased their interstate movement upon being sold to Blasius and were held at his discretion for resale. The assessment of the cattle for taxation occurred while they were in Minnesota, and the court concluded that they were part of the general mass of property within the state, thus subject to taxation.

The court determined that the cattle had ceased their interstate movement upon being sold to Blasius and were held at his discretion for resale. The assessment of the cattle for taxation occurred while they were in Minnesota, and the court concluded that they were part of the general mass of property within the state, thus subject to taxation.

Conclusion

The U.S. Supreme Court reversed the decision of the Minnesota Supreme Court, ruling that the cattle were subject to state taxation as they had come to rest in Minnesota.

The U.S. Supreme Court reversed the decision of the Minnesota Supreme Court, ruling that the cattle were subject to state taxation as they had come to rest in Minnesota.

Who won?

The State of Minnesota prevailed in the case because the U.S. Supreme Court found that the cattle were not in transit and had acquired a taxable situs within the state.

The State of Minnesota prevailed in the case because the U.S. Supreme Court found that the cattle were not in transit and had acquired a taxable situs within the state.

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