American Trucking Associations, Inc. v. Michigan Public Service Commission
The Supreme Court unanimously upheld Michigan's flat $100 annual fee on trucks that haul freight only within the state, ruling that the fee does not improperly burden interstate commerce.
Because the fee applies evenhandedly to all trucks doing local business in Michigan and does not tax interstate trips or discriminate against out-of-state companies, it survives scrutiny under the constitutional principle that keeps states from erecting trade barriers against each other.
“jeopardizing the welfare of the Nation as a whole”
Describes the core harm the dormant Commerce Clause is meant to prevent.
How it got here: Michigan's Court of Claims and Court of Appeals both upheld the fee; the state supreme court declined review, and the truckers asked the U.S. Supreme Court to step in.
The Case in Depth
What happened
A trucking company that hauls both across state lines and within Michigan, along with a national trucking trade group, challenged a Michigan law requiring a flat $100 annual fee for each truck used in purely in-state hauling. They argued the flat fee unfairly burdened trucks that also did interstate business, since those trucks did less local hauling than trucks operating only within Michigan.
The question before the Court
Could Michigan charge a flat $100 annual fee on trucks hauling freight only within the state without violating the Constitution's limits on burdening interstate trade?
The Court's answer
Yes — the Court ruled that Michigan's flat $100 fee on trucks doing purely local hauling does not violate the constitutional principle against states burdening trade across state lines. The fee applies only to activity happening entirely inside Michigan, treats all local haulers the same regardless of whether they also do interstate business, and does not tax any part of a truck's interstate journey.
The trucking companies argued the fee unfairly burdened trucks that split their time between interstate and local hauls, but they offered no evidence that the fee actually discouraged interstate trucks from picking up local loads or otherwise disadvantaged them. The Court also found the flat per-truck charge reasonable since the costs it covers — inspecting size, weight, and safety — don't clearly track miles driven, and distinguished this fee from earlier fees the Court had struck down that applied even to trucks with no local business at all.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
Trucking companies that mix interstate hauls with local Michigan deliveries must keep paying the flat fee, and states elsewhere can continue charging similar flat local fees on businesses operating in-state without fear of a Commerce Clause challenge, so long as the fees apply evenhandedly to local activity.
What changes now
This is a final merits decision affirming the Michigan Court of Appeals, so the $100 flat fee remains in effect and the trucking companies owe it going forward. No further proceedings are contemplated in this case, though the ruling leaves room for future challenges if a state's local fee structure were shown, with better evidence, to actually burden or discriminate against interstate trucking.
What this does not decide
The Court stressed that its ruling rested partly on a thin factual record showing no proven burden on interstate trade; it did not decide that all flat local fees on trucking or other local business are automatically valid, especially where evidence shows a real discriminatory or burdensome effect on interstate commerce.
Concurrences and dissents
Concurrence — Justice Scalia
Justice Scalia agreed the fee is constitutional but would not use the Court's multi-factor balancing tests. He would ask only two questions: whether the fee openly discriminates against interstate commerce on its face, and whether it resembles a type of law the Court has already struck down. Michigan's fee fails both tests for invalidity, so he would uphold it on that narrower basis.
Concurrence — Justice Thomas
Justice Thomas would affirm without relying on the dormant Commerce Clause doctrine at all, reiterating his view that this unwritten constitutional principle has no basis in the Constitution's text, makes little sense, and is unworkable, so it cannot be used to strike down state laws.
How the Court got there
The legal reasoning, step by step
- The Court applied its dormant Commerce Clause framework, the principle that states cannot pass laws that unfairly burden trade crossing state lines even though the Constitution does not say this explicitly; the question was whether Michigan's fee crossed that line.
- The Court noted the fee applied only to purely in-state hauls, applied evenhandedly to every truck doing that local business, and did not tax any part of a trip that crossed state lines, so it did not single out interstate commerce for worse treatment.
- The Court found no evidence in the record that the fee actually discouraged interstate trucks from picking up local Michigan loads or otherwise disrupted interstate business, and the trucking companies' own lawyer admitted at argument that no such proof existed.
- The Court explained that because the costs the fee covers — like inspecting truck size, weight, and safety — tend to vary by truck rather than by miles driven, charging a flat per-truck fee rather than a per-mile fee was a reasonable, non-discriminatory way to set the charge.
- The Court distinguished its earlier decision in Scheiner, which struck down fees that taxed interstate trucks even when they had no local business, because Michigan's fee applies only to genuinely local hauling and imposes no comparable barrier to entering the state.
- The Court rejected the 'internal consistency' argument that a truck doing local business in many states would owe large cumulative fees, reasoning that any business operating locally in multiple states normally expects to pay each state's uniformly applied local fee.
Doctrinal impact
Cases affected by this decision
Distinguishes American Trucking Assns., Inc. v. Scheiner (483 U. S. 266)
The Court said Scheiner's flat fees on all trucks entering a state differ from Michigan's fee on purely local hauling.