Minnesota v. National Tea Co.

Facts

D enacted a chain store tax on gross sales that was graduated to the volume of gross sales. Ps paid the gross sales tax under protest and then sued in the state court for refunds. The lower courts agreed with Ps and granted refunds. In its holding, the Supreme Court of Minnesota discussed not only the equal protection clause of the Fourteenth Amendment of the federal constitution but also  Art. 9, § 1 of the Minnesota constitution which provides: 'Taxes shall be uniform upon the same class of subjects . . .' It said that 'these provisions of the Federal and State Constitutions impose identical restrictions upon the legislative power of the state in respect to classification for purposes of taxation.' It quoted the conclusion of the lower Minnesota court that the statute violated both the federal and the state constitutions. The Court discussed three of its former decisions which had interpreted Art. 9, § 1 of the Minnesota constitution, and quoted from one of them. It then proceeded to a discussion of cases based solely on the Fourteenth Amendment of the federal constitution. Its analysis of the Fourteenth Amendment was specifically related to chain store taxation. It distinguished decisions that held that the number of stores in a given chain affords an appropriate basis for classification for the imposition of progressively higher taxes. It stated that the 'precise question here presented' had been directly passed upon adversely to the state's contention in five cases: Stewart Dry Goods Co. v. Lewis,  294 U.S. 550; Valentine v. Great Atlantic & Pacific Tea Co., 299 U.S. 32; Ed. Schuster & Co. v. Henry, 218 Wis. 506; 261 N. W. 20; Lane Drug Stores, Inc. v. Lee, 11 F.Supp. 672; Great Atlantic & Pacific Tea Co. v. Harvey, 107 Vt. 215; 177 A. 423. o. v. Lewis. It quoted with approval from the opinion in Ed. Schuster  & Co. v. Henry. D appealed. 

Issues

Rule of Law

Holding and Decision

Legal Analysis

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