Quill Corporation v. North Dakota (1991)
- Docket
- 91-194
- Decided
- 1991-01-01
Summary
Question: 1) Had Bellas Hess become obsolete? 2) Was North Dakota's imposition of a use tax upon the merchandise of the Quill Corporation in compliance with the Due Process Clause and the Commerce Clause? Conclusion: No and No. In a majority opinion authored by Justice John Paul Stevens, the Court admitted that, over time, subsequent cases have allowed for more flexibility than Bellas Hess . Nevertheless, the Court maintained that this evolution does not suggest a rejection of Bellas Hess . The Court also determined that North Dakota's imposition of the use tax did not constitute a breach of the Due Process Clause because the Quill Corporation had sufficient contact with the state's residents and benefited from the state's tax revenue. However, it found the use tax to be unconstitutional because it interfered with interstate commerce, rendering it a violation of the Commerce Clause. Consequently, the Court reversed the North Dakota Supreme Court's decision by ruling in favor of the Quill Corporation.