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Walling v. People, 116 U.S. 446, 6 S.Ct. 454, 29 L.Ed. 691

Facts

In June 1883, Walling was prosecuted under Michigan's 1875 law for selling and soliciting orders for spirituous liquors to be shipped from Chicago to Michigan without a license. Walling was convicted in the police court of Grand Rapids and sentenced to pay a fine and serve time in prison. He appealed the conviction, arguing that the law was unconstitutional as it conflicted with federal commerce regulations.

In June 1883, Walling was prosecuted under Michigan's 1875 law for selling and soliciting orders for spirituous liquors to be shipped from Chicago to Michigan without a license.

Issue

Is the Michigan statute of 1875 imposing a tax on the sale of liquors by non-residents unconstitutional as it discriminates against interstate commerce?

Is the Michigan statute of 1875 imposing a tax on the sale of liquors by non-residents unconstitutional as it discriminates against interstate commerce?

Rule

The U.S. Constitution grants Congress the exclusive power to regulate interstate commerce, and any state law that imposes a discriminatory tax on goods from other states is unconstitutional.

The U.S. Constitution grants Congress the exclusive power to regulate interstate commerce, and any state law that imposes a discriminatory tax on goods from other states is unconstitutional.

Analysis

The court analyzed the Michigan statute and determined that it imposed a tax specifically on non-resident sellers of liquor, which effectively discriminated against interstate commerce. The court referenced previous decisions that established the principle that states cannot impose taxes that favor their own products over those from other states, as this would violate the commerce clause of the Constitution.

The court analyzed the Michigan statute and determined that it imposed a tax specifically on non-resident sellers of liquor, which effectively discriminated against interstate commerce.

Conclusion

The Supreme Court of Michigan reversed the lower court's judgment, ruling that the 1875 statute was unconstitutional and void due to its discriminatory nature against interstate commerce.

The Supreme Court of Michigan reversed the lower court's judgment, ruling that the 1875 statute was unconstitutional and void due to its discriminatory nature against interstate commerce.

Who won?

Walling prevailed in the case because the court found the statute under which he was prosecuted to be unconstitutional, thus invalidating his conviction.

Walling prevailed in the case because the court found the statute under which he was prosecuted to be unconstitutional, thus invalidating his conviction.

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