Itel Containers International Corporation v. Joe Huddleston, Commissioner of Revenue of Tennessee (507 U.S. 60)
U.S. Supreme Court · decided February 23, 1993 · Supreme Court Database (Spaeth)
- Citation
- 507 U.S. 60 · 113 S. Ct. 1095
- Decided
- February 23, 1993
- Term
- October Term 1992
- Vote
- 8–1
- Majority author
- Justice Kennedy
- Issue area
- Economic Activity
- Disposition
- Affirmed
- Outcome
- Petitioning party lost
- Ideological direction
- Liberal
Opinion excerpt
Justice Kennedy delivered the opinion of the Court. In this case we consider the validity of a state tax affecting cargo containers used in international trade, a subject we have addressed once before. See Japan Line, Ltd. v. County of Los Angeles, 441 U. S. 434 (1979). We sustain Tennessee’s sales tax on leases of containers owned by a domestic company and used in international shipping. I The use of large steel containers to transport goods by-truck, rail, and oceangoing carrier was a major innovation in transportation technology. In 1990, the United States shipped, by value, 60% of its marine imports and 52% of its marine exports in these containers. Itel Containers International Corporation, the petitioner here, is a Delaware corporation with its principal place of business in California. Itel’s primary business is leasing cargo containers to participants in the international shipping industry, and all its leases restrict use of its containers to international commerce. The leases are solicited and negotiated through Itel marketing offices in California, Illinois, New Jersey, South Carolina, Texas, and Washington, and the leased containers are delivered to lessees or their agents in many of the 50 States, including Tennessee. The Tennessee deliveries occur either at Itel’s Memphis terminal or at several designated third-party terminals. In December 1986, the Tennessee…
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