United States Supreme Court Cases & Opinions

U.S. Supreme Court

Great Northern Ry. Co. v. Minnesota, 278 U.S. 503 (1929)

Great Northern Railway Company v. Minnesota

Nos. 106 and 107

Argued January 9, 1929

Decided February 18, 1929

278 U.S. 503

Syllabus

A state tax on the local property of a railway company measured upon gross receipts from intrastate business, and upon gross receipts from interstate business in the proportion which the mileage of the railway within the state bears to the entire mileage of the railway over which such interstate business is done, is not a burden to interstate commerce or violative of the due process and equal protection clauses of the Fourteenth Amendment, though part of the property devoted to interstate commerce consist of docks outside of the state at the terminus of a line running from within it, and though the compensation received for the services of such docks be included in the gross receipts of that line in computing the gross receipts attributable to the taxable part of it.

So held where the principal, and a very lucrative, business of the line in question was hauling ore from mines in the taxing state to the terminal docks, where the line and the docks were treated by the railway as a unit, the charge for dock service being

Page 278 U. S. 504

absorbed in the charge per ton transported, and where the evidence did not show that the mileage value of the part of the line outside of the taxing state, with the docks included, was greater than the mileage value of the part within it. P. 278 U. S. 508.

174 Minn. 3 affirmed.

Error to and appeal from a judgment of the Supreme Court of Minnesota sustaining a judgment for taxes in an action by the state against the Railway. See 160 Minn. 515; 273 U.S. 658. The writ of error was dismissed.

Page 278 U. S. 506