The legal case is about Montana's severance tax on coal production and whether it is constitutional and compliant with federal law and the Commerce Clause of the US Constitution. The Supreme Court applied the Complete Auto Transit test and found that the tax was not discriminatory against interstate commerce and fairly related to services provided by the state. The Court rejected the argument that the tax conflicted with federal law and concluded that the Commerce Clause does not give one state the right to control another state's resource development and depletion.
Commonwealth Edison Co. v. Montana (1981)
Supreme Court of the United States
453 U.S. 609, 69 L. Ed. 2d 884, 101 S. Ct. 2946, SCDB 1980-151, 1981 U.S. LEXIS 43
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