Storaasli v. Minnesota
Headline: Court upheld Minnesota’s motor-vehicle registration tax as applied to a soldier stationed on Fort Snelling, allowing the State to require payment and registration for vehicles using its public highways despite the federal reservation.
Holding: The Court ruled that Minnesota may impose its motor-vehicle registration excise on a nonresident soldier stationed at Fort Snelling because the tax targets the privilege of using state highways, not taxable property located outside the State.
- Allows states to require registration taxes for vehicles using state roads, even if owner is on federal reservation.
- Treats the fee as a privilege excise, not a property tax.
- Nonresident military cannot claim state-to-state exemption without a state registration.
Summary
Background
A member of the United States military stationed on the Fort Snelling reservation in Minnesota challenged a Minnesota motor-vehicle registration tax. The State listed the car as delinquent and entered judgment for the tax and penalty after the servicemember said the vehicle was registered under the reservation’s federal authority and had not used Minnesota roads beyond brief visits. Minnesota courts upheld the tax, and the owner appealed to the Supreme Court asserting equal protection and that the State could not tax property located on the federal reservation.
Reasoning
The Court framed the main question as whether the law taxed property located outside the State or charged for the privilege of using Minnesota’s public highways. The Court found the levy is an excise—a privilege tax—because it is charged for using state streets and highways and includes registration and plate requirements. The opinion noted the statute sometimes measures the charge by vehicle value but also sets minimums and applies only to vehicles using state roads. The Court rejected the claim of unconstitutional discrimination, explaining that exemptions in the statute favor vehicles registered in other States and that the appellant, having only federal reservation registration, did not fall within that exempt class.
Real world impact
The ruling allows Minnesota to enforce its vehicle registration fee against nonresident military stationed on the reservation when their cars use state highways. It confirms the fee is treated as a user privilege rather than a property tax and upholds the state court judgment requiring payment.
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