852
MACHINES CORP.
Opinion of the Court
The text of the Export Clause, on the other hand, expressly prohibits Congress from laying any tax or duty on exports. These textual disparities strongly suggest that shifts in the Court's view of the scope of the dormant Commerce Clause should not, and indeed cannot, govern our interpretation of the Export Clause. Cf. Richfield Oil Corp. v. State Bd. of Equalization, 329 U. S. 69, 75-76 (1946) (distinguishing accommodations made under the Commerce Clause from the express textual prohibition of the Import-Export Clause).
B
The Government's primary assertion is that modifications in our Import-Export Clause jurisprudence require parallel modifications in the Export Clause context. More specifically, the Government argues that our decisions in Michelin Tire Corp. v. Wages, 423 U. S. 276 (1976), and Department of Revenue of Wash. v. Association of Wash. Stevedoring Cos., 435 U. S. 734 (1978), establish that States may impose generally applicable, nondiscriminatory taxes even if those taxes fall on imports or exports. The Export Clause, the Government contends, is no more restrictive.
The Import-Export Clause, which is textually similar to the Export Clause, says in relevant part, "No State shall . . . lay any Imposts or Duties on Imports or Exports." U. S. Const., Art. I, § 10, cl. 2. Though minor textual differences exist and the Clauses are directed at different sovereigns, historically both have been treated as broad bans on taxation of exports, and in several cases the Court has interpreted the provisions of the two Clauses in tandem. For instance, in the Court's first decision interpreting the Import-Export Clause, Chief Justice Marshall said:
though we have long recognized negative implications of the Clause that prevent certain state taxation even when Congress has failed to legislate. See Fulton Corp. v. Faulkner, 516 U. S. 325, 330-331 (1996); Quill Corp. v. North Dakota, 504 U. S. 298, 309 (1992).
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