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Keywords

regulation

Related Cases

Wyoming v. Oklahoma, 502 U.S. 437, 112 S.Ct. 789, 117 L.Ed.2d 1, 60 USLW 4119, 129 P.U.R.4th 446

Facts

Wyoming, a major coal-producing state, does not sell coal but imposes a severance tax on coal extracted within its borders. From 1981 to 1986, Wyoming supplied nearly all the coal for four Oklahoma electric utilities. However, after Oklahoma enacted a law mandating a blend of at least 10% Oklahoma-mined coal, these utilities significantly reduced their purchases of Wyoming coal, leading to a decline in Wyoming's severance tax revenues. Wyoming sought to challenge the law under the Commerce Clause, claiming it was unconstitutional.

Wyoming, a major coal-producing State, does not sell coal, but does impose a severance tax on those who extract it. From 1981 to 1986, Wyoming provided virtually 100% of the coal purchased by four Oklahoma electric utilities, including the Grand River Dam Authority (GRDA), a state agency.

Issue

Did Wyoming have standing to challenge the Oklahoma law, and did the law violate the Commerce Clause?

Rule

The Commerce Clause prohibits states from enacting laws that discriminate against interstate commerce. States may not impose regulations that favor in-state products over out-of-state products without a legitimate justification.

The Commerce Clause prohibits states from enacting laws that discriminate against interstate commerce.

Analysis

The Court found that Wyoming had standing because the Oklahoma law directly affected its severance tax revenues, which could be traced back to the law's requirements. The Court also determined that the Oklahoma law discriminated against interstate commerce by favoring local coal over Wyoming coal without sufficient justification, thus violating the Commerce Clause.

The Court found that Wyoming had standing because the Oklahoma law directly affected its severance tax revenues, which could be traced back to the law's requirements.

Conclusion

The Supreme Court ruled that the Oklahoma law was unconstitutional under the Commerce Clause and that it was not severable, meaning the entire law was invalidated.

Ordered accordingly.

Who won?

Wyoming prevailed in the case because the Court found that the Oklahoma law violated the Commerce Clause and that Wyoming had standing to bring the suit.

Wyoming has standing. The prior rulings on standing in this case 'should be subject to the general principles of finality and repose, absent changed circumstances or unforeseen issues not previously litigated.'

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