The Supreme Court held that a state tax on imported goods that were still in the original packaging and not mixed with other goods violated both the imports-exports and the commerce clause.

A Maryland statute required importers of foreign goods to purchase a license. The state claimed that a license tax on the importer was different from a tax on the import itself. By a 6-1 vote, the Supreme Court struck down the law. Chief Justice John MarshallMarshall, John;Brown v. Maryland[Brown v. Maryland]enunciated the original packaging rule, which said that as long as imported goods were in the original packaging, a state tax was an unconstitutional violation of both the imports-exports and the commerce clause. Once imported goods became mixed up with other property, the state could tax them. This ruling enhanced federal powers without permanently insulating imported goods from state taxation.State taxation;Brown v. Maryland[Brown v. Maryland]

In 1869 the Court decided that the original packaging rule did not apply to goods moving in interstate commerce. In Michelin Tire Corp. v. Wages[case]Michelin Tire Corp. v. Wages[Michelin Tire Corp. v. Wages] (1976), the Court almost entirely abandoned the rule when it allowed states to assess nondiscriminatory property taxes on foreign imports in storage.

Commerce, regulation of

State taxation

Woodruff v. Parham