Hendrick v. Maryland

Background

An automobile owner who lived and worked in the District of Columbia drove into Prince George’s County, Maryland, and was arrested for operating his car on public roads without the registration certificate required by Maryland’s new Motor Vehicle Law effective July 1, 1910. He was tried before a Justice of the Peace, fined fifteen dollars, and appealed. The Circuit Court retried the case on an agreed statement of facts and the constitutionality of the statute was presented for decision.

Reasoning

The Court considered whether Maryland’s rules—requiring vehicle registration, numbered plates, and a $2 operator’s license, with registration fees graduated by engine horsepower and a limited nonresident exemption—violated federal protections or unduly burdened interstate travel. The Court said these requirements are proper exercises of the State’s power to protect public safety and maintain roads. It found the graduated fees tied to engine power reasonable, held that charging for special road facilities does not directly and materially burden interstate commerce, and noted the record contained no evidence showing the law was arbitrary or unfair. The petitioner also could not rely on a claim of discrimination because he had not met the statute’s conditions for an exemption.

Real world impact

The ruling allows Maryland and similarly situated States to enforce registration, license, and fee rules for drivers and to collect money for road maintenance. Motorists from other places must follow state registration and licensing rules or meet the statute’s temporary-exemption conditions to avoid fees. The Court affirmed the conviction and left to the States the primary role in setting and justifying such requirements based on safety and road-use costs.