8 Wall. (75 U.S.) 123 (1869), argued 13 Oct. 1869, decided 8 Nov. 1869 by vote of 8 to 1; Miller for the Court, Nelson in dissent. The plaintiffs refused to pay the Mobile, Alabama, tax on sales of goods at auction, contending that, since their goods were brought in from other states and sold in original packages they were exempt from taxation. They invoked the Constitution's prohibition against state taxation of imports and the Commerce Clause, stressing the original package doctrine established in Brown v. Maryland (1827). InBrown, the Court held that state power over commerce attached when a commodity lost its character as an import. While in its original package it remained a part of interstate commerce. In Woodruff the Court read the Brown precedent narrowly, holding that the Constitution did not prohibit one state from taxing articles imported from another provided the taxing state did not discriminate against such goods. As this case concerned a tax imposed on all sales made in Mobile, it did not discriminate against interstate commerce. Conversely, the opinion underscored the limitations of state power. States could not tax products of other states so as to drive them out of the jurisdiction or interfere with commerce between the states; a tax that attempted to fetter interstate commerce would be unconstitutional. Thus, the Woodruff decision helped to establish the principle that state discrimination against interstate commerce violated the Commerce Clause.
Richard F. Hamm