Complete Auto Transit was a Michigan corporation doing business in Mississippi. Complete shipped cars into the state where they were distributed for sale. Mississippi imposed a tax on transportation companies for the "privilege of doing business" in the state. The tax was applied equally to businesses involved in intra- and interstate commerce.
Did the Mississippi tax violate the Commerce Clause because it placed a burden on an activity associated with interstate commerce?
A unanimous Court found the tax valid. Businesses involved in interstate commerce should assume a just share of the state tax burden. The Court's decision established four criteria to be met for a state tax to be valid and not an unreasonable burden on interstate commerce. The tax must be (1) on an activity connected to the state, (2) fairly apportioned to be based on intrastate commerce, (3) nondiscriminatory, and (4) related to state services provided. These criteria are only valid if Congress has not imposed conflicting regulations.
Decisions
Decision: 9 votes for Brady, 0 vote(s) against Legal provision: Article 1, Section 8, Paragraph 3: Interstate Commerce Clause
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Full Opinion by Justice Harry A. Blackmun
