Spector Motor Service, Inc. v. O'connor, Tax Commissioner (340 U.S. 602)
U.S. Supreme Court · decided March 26, 1951 · Supreme Court Database (Spaeth)
- Citation
- 340 U.S. 602 · 71 S. Ct. 508
- Docket
- No. 132
- Argued
- October 29, 1950; reargued January 10, 1951
- Decided
- March 26, 1951
- Term
- October Term 1950
- Vote
- 6–3
- Majority author
- Justice Burton
- Issue area
- Economic Activity
- Disposition
- Reversed
- Outcome
- Petitioning party won
- Ideological direction
- Conservative
- Constitutional ruling
- State/territorial law held unconstitutional
How the Justices voted
- Majority
- Chief Justice Vinson, Justice Minton, Justice Burton (wrote), Justice R. H. Jackson, Justice Frankfurter, Justice Reed
- Dissenting
- Justice Clark (wrote), Justice Douglas, Justice Black
Opinion excerpt
Mr. Justice Burton delivered the opinion of the Court. This proceeding attacks, under the Commerce Clause of the Constitution of the United States, the validity of a state tax imposed upon the franchise of a foreign corporation for the privilege of doing business within the State when (1) the business consists solely of interstate commerce, and (2) the tax is computed at a nondiscriminatory rate on that part of the corporation’s net income which is reasonably attributable to its business activities within the State. For the reasons hereinafter stated, we hold this application of the tax invalid. Petitioner, Spector Motor Service, Inc., is a Missouri corporation engaged exclusively in interstate trucking. It instituted this action in 1942 in the United States District Court for the District of Connecticut against the Tax Commissioner of that State. It sought to enjoin collection of assessments and penalties totaling $7,795.50, which had been levied against it, for various periods between June 1, 1935, and December 31, 1940, under the Connecticut Corporation Business Tax Act of 1935 and amendments thereto. It asked also for a declaratory judgment as to its liability, if any, under that Act. It claimed that the tax imposed by the Act did not apply to it and that, if it did, such application violated both the Connecticut Constitution and the Commerce and Due Process Clauses of…
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