Blue Star Line, Inc. v. City & County of San Francisco

Opinion

RATTIGAN, J.

Respondent City and County of San Francisco levies a tax upon the payrolls of employers who conduct business within its territorial limits. In two actions brought against it by appellants and other plaintiffs, they asserted the claim that various provisions of the United States Constitution invalidated the levy, as to them, because their local business activity engaged them in maritime foreign commerce at the ocean port of San Francisco. The appeal is from a portion of a *432declaratory judgment, entered in the actions as consolidated, which denies the constitutional claim as…