Mayo v. United States

Background

The United States bought commercial fertilizer outside Florida and, under the Soil Conservation and Domestic Allotment Act, distributed those bags to farmers in Florida as part of a federal soil-conservation program. The fertilizer helped grow winter legumes to add nitrogen to fields. Florida law required inspection stamps and allowed seizure and sale of unstamped bags. When Florida ordered local associations to stop sales of unstamped fertilizer, the federal government sued to stop the state from enforcing that law.

Reasoning

The Court found that the United States owned the fertilizer and was distributing it as part of a governmental program, not acting as a private seller. Because the payments would have been direct money exactions on the federal government, the Court held that Florida could not require payment of inspection fees or force compliance with its stamp rule without clear congressional permission. The Court relied on the supremacy of federal operations and distinguished cases about taxes on private persons or employees.

Real world impact

The practical effect is that Florida cannot stop or tax the federal distribution of fertilizer used in the national soil program, and unstamped federal fertilizer cannot be seized or sold under the state law. The ruling keeps the conservation program on schedule because farmers can receive fertilizer when needed for planting. States may still regulate purely private sales, but not federal operations in this context.

Dissents or concurrances

One district judge dissented from the injunction, and Justice Black agreed only with the outcome. The opinion notes disagreement about how far state rules can reach when federal agencies act, but the Court affirmed federal immunity here.