Coe v. Errol (1886)

Case Facts: Coe received a tax bill of the Town of Errol for the value of logs that were stored there.  The logs, some of which had been cut in New Hampshire and some in Maine were stuck on the Androscoggin River waiting for spring floods to move the logs to Maine.  Coe argued that the logs were part of interstate commerce and were covered under the commerce clause.  New Hampshire ruled that the logs cut in Maine were not to be taxed but that the logs cuts in New Hampshire were properly taxed.

Issue/s: Are products (held by) a state able to be taxed, constitutionally, even if they are intended to be exported to another state

Holding/reasoning: No.

Regardless if the property is at rest while it waits to be transported or even if it’s just waiting to be sold at its final destination, it is subject to taxes BUT if it is in transit from one state to another it is then considered interstate commerce and is exempt from local taxation.  National control comes when the goods have actually been shipped or are on a continuous journey to their destination.  Since the logs in New Hampshire had not yet been shipped they were subject to New Hampshire taxes.

References:

https://www.nhbar.org/uploads/pdf/PatriotsPiratesProfitSeekersPoliticians-Vol2-TeachersEdition.pdf

Reports of Cases Argued and Determined in the Supreme Court…Vol. 75

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