Allgeyer v. Louisiana

165 U.S. 578 (1897)

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Allgeyer v. Louisiana

United States Supreme Court
165 U.S. 578 (1897)

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Facts

A Louisiana state law prohibited Louisiana corporations from doing business with out-of-state marine-insurance companies that had not complied with the state’s insurance regulations, such as having an in-state agent. E. Allgeyer and Company (Allgeyer) (defendant), a Louisiana-based cotton exporter, entered into a contract with the Atlantic Mutual Insurance Company (Atlantic Mutual) in New York to insure an international shipment of cotton. Atlantic Mutual had not complied with Louisiana’s state insurance regulations for doing business in Louisiana. The State of Louisiana (plaintiff) filed a petition in Louisiana state court, alleging that Allgeyer had violated the state law by doing business with a noncompliant out-of-state insurer. The evidence showed that the insurance contract was formed in New York and was to be executed entirely in New York, from paying premiums to adjusting losses. The only allegedly illegal act that occurred in Louisiana was a communication that Allgeyer mailed from Louisiana to Atlantic Mutual in New York with information about the cotton. Allgeyer argued that the fine unconstitutionally deprived it of its property without due process of law. The trial court found that the state law was unconstitutional. The Louisiana Supreme Court reversed and fined Allgeyer. The United States Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Peckham, J.)

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