Limbach, Tax Commissioner of Ohio v. Hooven & Allison Co. (466 U.S. 353)
U.S. Supreme Court · decided April 18, 1984 · Supreme Court Database (Spaeth)
- Citation
- 466 U.S. 353 · 104 S. Ct. 1837
- Decided
- April 18, 1984
- Term
- October Term 1983
- Vote
- 9–0
- Majority author
- Justice Blackmun
- Issue area
- Economic Activity
- Disposition
- Vacated and remanded
- Outcome
- Petitioning party won
- Ideological direction
- Liberal
Opinion excerpt
Justice Blackmun delivered the opinion of the Court. In Hooven & Allison Co. v. Evatt, 324 U. S. 652 (1945) (Hooven I), this Court passed upon the constitutionality of Ohio’s application of a nondiscriminatory ad valorem personal property tax to imported fibers still in their original packages. The result there was unfavorable to the State. In this case, the Tax Commissioner of Ohio asks us to sustain the application of the same nondiscriminatory ad valorem personal property tax to like fibers, still in their original packages, imported by the same manufacturer. The case thus presents, primarily, an issue of preclusion framed in terms of collateral estoppel. I The Hooven & Allison Company (Hooven) is a domestic manufacturer of cordage products made from natural fibers. These fibers — hemp, sisal, jute, manila, and the like — are not grown in the United States and must be imported. Upon their arrival in this country, the imported fibers are transported by rail to Hooven’s plant in Xenia, Ohio, where they are stored in their original packages for future use in Hooven’s manufacturing process. In accord with Ohio Rev. Code Ann. §5711.16 (1980), Hooven timely filed personal property tax returns for 1976 and 1977. In those returns, Hooven listed these original-package imported fibers as “imports,” but deducted their value from the total value of its manufacturing inventory. The…
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