Interstate Busses Corp. v. Blodgett

Background

A Connecticut corporation that runs motor buses between Connecticut and points in Massachusetts and Rhode Island sued Connecticut tax officials. The company challenged a 1925 state law that charges one cent per mile for motor vehicles used in interstate commerce, with proceeds for highway maintenance. The company had already paid general vehicle registration and property taxes and argued the mileage tax, combined with other charges, unlawfully discriminated against interstate carriers because intrastate bus companies pay a separate 3% gross receipts excise instead.

Reasoning

The Court addressed whether the mileage tax unfairly burdened interstate commerce. It explained that a state may charge for the use of its highways, but a complaining carrier must show the tax falls with disproportionate economic weight on interstate activity. The Court found the statutes differed in form but the record did not contain any proof that the mileage tax imposed a substantially greater burden in practice. The company made no attempt to quantify the aggregate economic effect. Because the carrier failed to show discrimination or disproportionality, the Court affirmed the lower court’s dismissal.

Real world impact

The decision allows Connecticut to keep enforcing the one-cent-per-mile tax on interstate buses and use the revenue for highway maintenance. Interstate bus operators challenging similar taxes will need clear, factual proof that the tax places an unequal economic burden on them. The Court did not decide whether a state may suspend registration to enforce unpaid taxes because the challenge to the tax itself failed.