Case Citator › Baltic Mining Co. v. Massachusetts

Baltic Mining Co. v. Massachusetts

Is it still good law? What later courts have actually done to this case.

Overruled
Court
Supreme Court of the United States
Citation
231 U.S. 68
Decided
Confirmed treatments
2
Flagged citations read
17 of 17
Citing cases (total)
17
Treatment dates
1914–1925
Overruled
A reviewed court has overruled this case. Overruled. Alpha Portland Cement Co. v. Massachusetts disapproved Baltic Mining's suggestion that the size or label of a state tax could save a burden on interstate commerce or property outside the state.
More on how this was screened

In Western & Southern Life Insurance Co. v. State Board of Equalization, the Supreme Court later called Baltic Mining “overruled on other grounds” by Alpha Portland Cement. Its ruling on a capped tax for substantial local business was applied in other opinions. All 17 flagged citations have been read. The Constitution Annotated lists Alpha Portland Cement as the overruling decision.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

17 later cases cite Baltic Mining Co. v. Massachusetts; 17 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Baltic Mining Co. v. Massachusetts?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Overruled

  • The Supreme Court disapproved Baltic Mining's suggestion that a state's privilege tax could burden interstate commerce or property outside the state if the amount was limited.

    Alpha Portland Cement Co. v. Massachusetts · Supreme Court of the United States · filed

    It must now be regarded as settled that a State may not burden interstate commerce or tax property beyond her borders under the guise of regulating or taxing, intrastate business. So to burden interstate commerce is prohibited by the Commerce Clause; and the Fourteenth Amendment does not permit taxation of property beyond the State’s jurisdiction. The amount demanded is unimportant when there is no legitimate basis for the tax. So far as. the language of Baltic Mining Co. v. Massachusetts, 231 U. S. 68, 87, tends to support a different view it conflicts with conclusions reached in later opinions and is now definitely disapproved.
    Read the full opinion on CourtListener →

Criticized

  • The California Supreme Court questioned Baltic Mining's distinction between an excise and a tax on property, while applying its result to California's fees.

    Albert Pick & Co. v. Jordan · Supreme Court of California · filed

    These cases (Baltic Mining Co. and S. S. White Dental Mfg. Co. v. Commonwealth of Massachusetts, 231 U. S. 68, [58 L. Ed. 127, 34 Sup. Ct. Rep. 15]) ... The supreme court of the United States adopts without reservation the determination of the supreme court of Massachusetts that this fee is an excise tax as distinguished from a property tax. ... To say that because a tax is an excise it is not levied upon property is to throw all the reasoning of the supreme court in all these cases to the four winds.
    Read the full opinion on CourtListener →

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