Cite as: 511 U. S. 641 (1994)
Opinion of the Court
torney General, and Gretchen Garrison and Jeffrey K. Elnicki, Assistant Attorneys General. George Alex Bartlett, Clifton S. Elgarten, and Stuart H. Newberger filed a brief for respondents Delong's Incorporated et al.*
Justice Thomas delivered the opinion of the Court.
The State of Missouri imposes a uniform, statewide use tax on all goods purchased outside the State and stored, used, or consumed within the State. Although the tax is purportedly designed to "compensate" for sales taxes imposed by local jurisdictions on sales of goods in the State, local sales tax rates vary widely, and in many jurisdictions the use tax exceeds the sales tax. Petitioners contend that this system discriminates against interstate commerce in violation of the Commerce Clause, even though the local sales taxes across the State may, in the aggregate, place a greater burden on intrastate trade than the uniform use tax places on interstate trade. We agree that, in localities where the use tax exceeds the sales tax, the system is impermissibly discriminatory, and we therefore reverse the judgment of the Supreme Court of Missouri.
I
Missouri has a multitiered system of sales and use taxes. The State imposes by statute a tax of 4% on all sales of personal property in the State, Mo. Rev. Stat. § 144.020 (1986), and, through provisions in the State Constitution, provides for additional sales taxes of one-eighth of one percent and one-tenth of one percent on the same transactions. Mo. Const., Art. IV, §§ 43(a), 47(a). These levies are exactly
*Daniel J. Popeo and Richard A. Samp filed a brief for the Washington Legal Foundation as amicus curiae urging reversal.
Briefs of amici curiae urging affirmance were filed for the City of St. Louis et al. by Nancy Kelley Yendes; for the Multistate Tax Commission by Alan H. Friedman and Paull Mines; and for the National Conference of State Legislatures et al. by Richard Ruda and Lee Fennell.
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