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Standard Oil Co. of California v. Johnson

United States Supreme Court
316 U.S. 481 (1942)


Standard Oil Company of California (Standard Oil) (plaintiff) distributed gasoline to United States Army Post Exchanges in California. The California Motor Vehicle Fuel License Tax Act imposed a per-gallon license tax on the privilege of distributing gasoline. Section 10 of the Act made the tax inapplicable to any gas sold to “the government of the United States or any department thereof for official use of said government.” The state taxed Standard Oil for the fuel sold to the Exchanges, and Standard Oil paid the tax under protest. Standard Oil brought suit in the Superior Court of Sacramento County against the state in the name of state official Johnson (defendant), arguing that the Exchanges were exempt from the tax under § 10 of the Act, or, in the alternative, that the Act was unconstitutional for illegally burdening the federal government. The trial court ruled for the state, and the Supreme Court of California affirmed. The United States Supreme Court granted certiorari, because the state statute in question was alleged to have been contrary to the United States Constitution.

Rule of Law


Holding and Reasoning (Black, J.)

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