Quill Corporation v. North Dakota BY and Through Its Tax Commissioner, Heidi Heitkamp (504 U.S. 298)
U.S. Supreme Court · decided May 26, 1992 · Supreme Court Database (Spaeth)
- Citation
- 504 U.S. 298 · 112 S. Ct. 1904
- Decided
- May 26, 1992
- Term
- October Term 1991
- Vote
- 8–1
- Majority author
- Justice Stevens
- Issue area
- Economic Activity
- Disposition
- Reversed and remanded
- Outcome
- Petitioning party won
- Ideological direction
- Conservative
- Constitutional ruling
- State/territorial law held unconstitutional
Opinion excerpt
Justice Stevens delivered the opinion of the Court. This case, like National Bellas Hess, Inc. v. Department of Revenue of Ill., 386 U. S. 753 (1967), involves a State’s attempt to require an out-of-state mail-order house that has neither outlets nor sales representatives in the State to collect and pay a use tax on goods purchased for use within the State. In Bellas Hess we held that a similar Illinois statute violated the Due Process Clause of the Fourteenth Amendment and created an unconstitutional burden on interstate commerce. In particular, we ruled that a “seller whose only connection with customers in the State is by common carrier or the United States mail” lacked the requisite minimum contacts with the State. Id., at 758. In this case, the Supreme Court of North Dakota declined to follow Bellas Hess because “the tremendous social, economic, commercial, and legal innovations” of the past quarter-century have rendered its holding “obsolete].” 470 N. W. 2d 203, 208 (1991). Having granted certiorari, 502 U. S. 808, we must either reverse the State Supreme Court or overrule Bellas Hess. While we agree with much of the state court’s reasoning, we take the former course. I Quill is a Delaware corporation with offices and warehouses in Illinois, California, and Georgia. None of its employees work or reside in North Dakota, and its ownership of tangible property in that…
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