Department of Revenue v. Ass'n of Washington Stevedoring Companies

For the second time in this century, the State of Washington would apply its business and occupation tax to stevedoring. The State’s first application of the tax to stevedoring was unsuccessful, for it was held to be unconstitutional as violative of the Commerce Clause 1 of the United States Constitution. Puget Sound Stevedoring Co. v. State Tax Comm’n, 302 U. S. 90 (1937). The Court now faces the question whether Washington’s second attempt violates either the Commerce Clause or the Import-Export Clause.2

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Stevedoring is the business of loading and unloading cargo from ships.3 Private…