Glenn v. Field Packing Co.

Background

A margarine manufacturer, Field Packing Company, sued Kentucky’s State Tax Commission to stop enforcement of a 1932 law that imposed a ten‑cent per pound tax on all oleomargarine sold in the state. The company argued the law violated Kentucky’s Bill of Rights and was, in effect, a ban on selling oleomargarine rather than a real tax. A three‑judge federal district court first granted a temporary injunction and later entered a final decree making that block permanent. The company specifically challenged chapter 158 of the 1932 Kentucky laws that imposed the tax.

Reasoning

The core question was whether the ten‑cent tax was really a valid tax or really a prohibition on sales. The district court found the law functioned as a prohibition and was invalid under the state constitution, so it favored the margarine company. The Supreme Court did not decide any federal due‑process question. Instead, it agreed that state constitutional issues should be resolved ultimately by the state’s courts and that the lower court’s findings were supported by existing Kentucky authority.

Real world impact

The Court modified the lower court’s decree so the State Tax Commission can at any time return to the federal court and ask for a new order if the Kentucky courts later uphold the law or if conditions change so the law could be treated as a valid tax. For now, the ten‑cent tax cannot be enforced, but that protection is not permanent if state rulings or facts change. The Court cited older decisions about changing circumstances to justify this limited reopening.