Northwest Airlines, Inc. v. County of Kent, 510 U.S. 355, 19 (1994)

Page:   Index   Previous  12  13  14  15  16  17  18  19  20  21  22  23  24  25  26  Next

Cite as: 510 U. S. 355 (1994)

Opinion of the Court

the large and diverse general aviation population served by the Airport travels typically intrastate and seldom ventures beyond Michigan's borders.18

III

The Airlines assert that, even if the Airport's user fees are not unreasonable under the AHTA, they violate the "dormant" Commerce Clause. Even if we considered the AHTA's express permission for States' imposition of "reasonable rental charges, landing fees, and other service charges from aircraft operators for the use of airport facilities," 49 U. S. C. App. § 1513(b), insufficiently clear 19 to rule out judicial dormant Commerce Clause analysis,20 petitioners' argu-18 The Airlines suggest that they had no opportunity to develop a record demonstrating discrimination in favor of intrastate carriers, because the District Court granted summary judgment for respondents on the Commerce Clause question. See Reply Brief for Petitioners 9-10, n. 14. This argument does not fly. The case did proceed to trial on the AHTA claim. The Airlines have asserted that Evansville's standard governs AHTA reasonableness. Thus, under their own theory, they had to demonstrate the equivalent of a violation of the dormant Commerce Clause—i. e., discrimination against interstate commerce—in order to prevail at the AHTA trial. The Airlines' belated suggestion—which contradicts their endorsement of Evansville, see Brief for Petitioners 22-23—that discrimination in favor of intrastate commerce is relevant under the Commerce Clause, but not under the AHTA, is unimpressive. The AHTA was a direct response to Evansville; Congress' principal concern in enacting the measure was to proscribe fees that unduly burden interstate commerce. See, e. g., S. Rep. No. 93-12, p. 17 (1973). Covered fees, as we have emphasized, include, but are not limited to, head taxes. See supra, at 365-366, and n. 9.

19 See, e. g., Wyoming v. Oklahoma, 502 U. S. 437, 458 (1992) (requiring that Congress "manifest its unambiguous intent before a federal statute will be read to permit" state regulation discriminating against interstate commerce).

20 See, e. g., Merrion v. Jicarilla Apache Tribe, 455 U. S. 130, 154 (1982) ("Once Congress acts, courts are not free to review state taxes or other regulations under the dormant Commerce Clause. When Congress has struck the balance it deems appropriate, the courts are no longer needed to prevent States from burdening commerce, and it matters not that the

373

Page:   Index   Previous  12  13  14  15  16  17  18  19  20  21  22  23  24  25  26  Next

Last modified: October 4, 2007