Hendrick v. Maryland
The Court upheld Maryland's motor vehicle law requiring out-of-state drivers, including a Washington, D.C. resident who briefly drove into the state, to register their cars and obtain operator's licenses before using its highways.
The ruling established that states may use their police power to regulate and charge reasonable fees for interstate vehicles using state-built roads, so long as the fees are reasonable and don't function as a disguised tax on interstate travel or commerce.
How it got here: A Justice of the Peace convicted and fined Hendrick; he appealed to the Maryland Circuit Court, which tried the case anew on agreed facts and ruled against him, and he brought a writ of error to the Supreme Court.
The Case in Depth
What happened
John Hendrick, a Washington, D.C. resident, drove his own car from his office into Prince George's County, Maryland, without having obtained the certificate of registration Maryland's new Motor Vehicle Law required of anyone operating a car on its highways. He was arrested, tried before a local justice of the peace, found guilty, and fined fifteen dollars for failing to register his vehicle.
The question before the Court
Could Maryland require a Washington, D.C. driver to register his car and get a license before driving it on Maryland's highways?
Why it matters
The decision let states charge every driver, including those just passing through from another state or the District of Columbia, registration and license fees to fund road construction and safety enforcement. This gave states a durable tool to regulate the new and rapidly growing automobile traffic on their highways without running afoul of the Constitution's protections for interstate commerce and travel.
What changes now
This was a final merits decision resolving Hendrick's constitutional challenge; the Maryland Circuit Court's judgment fining him for failing to register his car was affirmed. The ruling left Maryland's registration and licensing scheme, including its fee structure and limited exemption for nonresidents from states with reciprocal registration laws, fully in effect and provided a framework other states could rely on for their own motor vehicle regulations.
What this does not decide
The Court expressly declined to decide whether Maryland's law actually discriminated against District of Columbia residents, since Hendrick had not shown he met the law's prerequisites for the nonresident exemption and so lacked standing to raise that claim.
Concurrences and dissents
How the Justices voted
Majority (1). Justice McReynolds (author).
How the Court got there
The legal reasoning, step by step
- The Court held that, absent conflicting federal legislation, a state may prescribe uniform safety regulations for all motor vehicles on its highways, including those engaged in interstate commerce, as an exercise of its police power — the government's basic authority to protect public health, safety, and order.
- Drawing on Smith v. Alabama, the Court explained that state licensing requirements for those using public facilities are part of ordinary local law that governs commerce until Congress displaces them with its own rules, rather than being direct regulations of interstate commerce themselves.
- Because Maryland had built and maintained an expensive system of roads, the Court reasoned the state could charge reasonable, uniformly applied compensation for their use, graduated by a vehicle's horsepower as a practical stand-in for its size and wear on the roads.
- The Court distinguished Crandall v. Nevada, explaining that case involved a direct tax on a person for the privilege of leaving the state, whereas Maryland's law was a regulatory and compensatory fee for using state highways, not a toll on travel itself.
- Because Hendrick had not shown he complied with District of Columbia registration laws or applied for Maryland's temporary out-of-state tag, the Court found he had no standing to claim the law's separate nonresident exemption unlawfully discriminated against District residents.
- Since nothing in the record showed the fees were arbitrary, unreasonable, or a disguised revenue tax rather than compensation for road use, the Court concluded the classifications based on horsepower were permissible.
Doctrinal impact
Cases affected by this decision
Distinguishes Crandall v. Nevada (6 Wall. 35)
Says that case involved a direct tax on leaving the state, unlike Maryland's regulatory highway-use fee.
Reaffirms Smith v. Alabama (124 U. S. 465)
Relies on it to hold that state licensing laws are local law, not direct regulation of interstate commerce.