Department of Revenue of Oregon v. ACF Industries, Inc., et al. (510 U.S. 332)
U.S. Supreme Court · decided January 24, 1994 · Supreme Court Database (Spaeth)
- Citation
- 510 U.S. 332 · 114 S. Ct. 843
- Decided
- January 24, 1994
- Term
- October Term 1993
- Vote
- 8–1
- Majority author
- Justice Kennedy
- Issue area
- Economic Activity
- Disposition
- Reversed and remanded
- Outcome
- Petitioning party won
- Ideological direction
- Liberal
Opinion excerpt
Justice Kennedy delivered the opinion of the Court. The power of state and local governments to impose ad valorem property taxes upon railroads and other interstate carriers has been the source of recurrent litigation under the Commerce Clause and the Due Process Clause. See, e.g., Central R. Co. of Pa. v. Pennsylvania, 370 U. S. 607 (1962); Braniff Airways, Inc. v. Nebraska Bd. of Equalization and Assessment, 347 U. S. 590 (1954); Morgan v. Parham, 16 Wall. 471 (1873). In the case before us, a state property tax is challenged under a federal statute, the Railroad Revitalization and Regulatory Reform Act of 1976 (4-R Act). Pub. L. 94-210, 90 Stat. 31. The question presented is whether the State of Oregon violated the statute by imposing an ad valorem tax upon railroad property while exempting various other, but not all, classes of commercial and industrial property. We hold that a State may grant exemptions from a generally applicable ad valorem property tax without subjecting the taxation of railroad property to challenge under the relevant provision of the 4-R Act, §306(l)(d), 49 U. S. C. § 11503(b)(4). I Oregon imposes an ad valorem tax upon all real and personal property within its jurisdiction, except property granted an express exemption. Ore. Rev. Stat. §307.030 (1991). Various classes of business personal property are exempt, including agricultural machinery and…
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