A. Magnano Co. v. Hamilton
292 U.S. 40 (1934)

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U.S. Supreme Court

A. Magnano Co. v. Hamilton, 292 U.S. 40 (1934)

A. Magnano Co. v. Hamilton

No. 589

Argued March 7, 1934

Decided April 2, 1934

292 U.S. 40

Syllabus

A statute of the State of Washington lays a tax of fifteen cents per pound on all butter substitutes, including oleomargarine, sold within the State.

Held:

1. In respect of the equal protection clause it is obvious that the differences between butter and oleomargarine are sufficient to justify their separate classification for purposes of taxation. P. 292 U. S. 43.

2. The requirement that a tax shall be for a public purpose has regard to the use to be made of the revenue derived from the tax. Its purpose may be public, although the motive behind it may have been to benefit one industry (dairying) by burdening another (oleomargarine). P. 292 U. S. 43.

3. The statute in question imposes no burden on interstate commerce. P. 292 U. S. 43.

4. The effect on an individual of an interference with federal taxing power, caused by destruction of a potential source of federal taxes through excessive state taxation, is too speculative, indirect, and remote to afford the individual any equitable standing in a suit to enjoin the state tax on the ground of such interference. P. 292 U. S. 43.

5. In general, the due process clause of the Fourteenth Amendment, applied to the States, like the due process clause of the Fifth Amendment, applied to Congress, is not a limitation upon the taxing power. P. 292 U. S. 44.

6. The due process clause applies if the Act be so arbitrary as to compel the conclusion that it does not involve an exertion of

Page 292 U. S. 41

the taxing power, but constitute, in substance and effect, the direct exertion of a different and forbidden power, as, for example, the confiscation of property. P. 292 U. S. 44.

7. Collateral purposes or motives of a legislature in levying a tax of a kind within the reach of its lawful power are matters beyond the scope of judicial inquiry. P. 292 U. S. 44.

8. A tax otherwise within the lawful power of a state cannot be adjudged contrary to due process merely because its enforcement may or will result in restricting or even destroying particular occupations or businesses. P. 292 U. S. 44.

2 F.Supp. 414, 17, affirmed.

Appeal from a decree dismissing the bill in a suit to enjoin collection of an excise tax on the business of selling oleomargarine within the State.

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