Couchot v. State Lottery Commission

The only issues before the court are whether the relevant portions of Am.Sub.H.B. No. Ill, as applied to nonresident lottery winners under the facts of this case, violate due process, interfere with interstate commerce, or constitute unlawful retroactive legislation.4

I

The court of appeals determined that Am.Sub.H.B. No. Ill, as applied in this case, violates due process because Ohio lacked a sufficient nexus with Couchot to exercise the authority to tax his lottery winnings. The court determined that while Ohio would have had the constitutional authority to tax Couchot on his lottery winnings…