Henneford v. Silas Mason Co. case brief

Henneford v. Silas Mason Co. case brief summary
300 U.S. 577 (1937)

CASE SYNOPSIS

Defendant Tax Commission of Washington appealed a judgment of the District Court of the United States for the Eastern District of Washington, which held unconstitutional a tax on the use of chattels bought in other states and brought into the State of Washington and used there, in plaintiff taxpayers' action assailing 1935 Wash. Laws 180 as a violation of the Commerce Clause, U.S. Constitutional art. I, § 8.

CASE FACTS
The taxpayers were contractors and subcontractors in the construction of a dam, during the construction of which they brought into the State of Washington machinery, materials, and supplies that were bought at retail in other states. The Commission informed the taxpayers that they were subject, through the use of this property, to a use tax pursuant to 1935 Wash. Laws 180. The taxpayers filed the instant action on the ground that the tax violated the Commerce Clause as a tax on interstate commerce or a discrimination against such commerce obstructing or burdening it unlawfully, and the district court agreed.

DISCUSSION

• On appeal, the United States Supreme Court reversed, holding that: 
• 1) the tax was not upon the operations of interstate commerce, but upon the privilege of use after commerce was at an end; and 
• 2) the tax upon the use after the property was at rest was not so measured or conditioned as to hamper the transactions of interstate commerce or discriminate against them. 
• The Court further noted that the legislature could make the tax base as broad or as narrow as it pleased, and such questions of fiscal policy were not for the Court to decide.

CONCLUSION
The Court reversed the district court's judgment.

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