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Oklahoma Tax Commission v. Jefferson Lines, Inc.

United States Supreme Court

514 U.S. 175, 115 S. Ct. 1331 (1995)

Facts

Jefferson Lines, Inc. (Jefferson) (defendant) was a Minnesota corporation that provided bus services in Oklahoma. Jefferson collected sales taxes on tickets sold in Oklahoma for bus trips that traveled exclusively within Oklahoma but did not collect sales taxes on trips that began in Oklahoma and ended in another state. In 1989 Jefferson filed for bankruptcy. The Oklahoma Tax Commission (plaintiff) filed a claim in bankruptcy court, seeking uncollected sales taxes on tickets for interstate travel sold by Jefferson. Jefferson disputed the claim, arguing that the Commerce Clause of the United States Constitution prevented Oklahoma from collecting sales taxes on the full price of tickets for interstate travel because some of the value of the tickets came from states other than Oklahoma. The bankruptcy court held for Jefferson, and the district court affirmed. The United States Court of Appeals for the Eighth Circuit affirmed the district court, holding that the application of Oklahoma’s sales tax on the full price of bus tickets for interstate travel violated the Commerce Clause because the tax was not fairly apportioned. The United States Supreme Court granted certiorari.

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Holding and Reasoning (Souter, J.)

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Dissent (Breyer, J.)

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