564
OCTOBER TERM, 1996
Syllabus
certiorari to the supreme judicial court of maine
No. 94-1988. Argued October 9, 1996—Decided May 19, 1997
Petitioner, a Maine nonprofit corporation, operates a church camp for children, most of whom are not Maine residents. Petitioner is financed through camper tuition and other revenues. From 1989 to 1991, it paid over $20,000 per year in real estate and personal property taxes. A state statute provides a general exemption from those taxes for charitable institutions incorporated in Maine. With respect to institutions operated principally for the benefit of Maine nonresidents, however, a charity may only qualify for a more limited tax benefit, and then only if its weekly charge for services does not exceed $30 per person. Petitioner was ineligible for any exemption, because its campers were largely nonresidents and its weekly tuition was roughly $400 per camper. After respondent town of Harrison (Town) rejected its request for a refund of taxes already paid and a continuing exemption from future taxes, which was based principally on a claim that the tax exemption statute violated the Commerce Clause, petitioner filed suit and was awarded summary judgment by the Superior Court. The Maine Supreme Judicial Court reversed, holding that petitioner had not met its burden of persuasion that the statute is unconstitutional.
Held: An otherwise generally applicable state property tax violates the
Commerce Clause if its exemption for property owned by charitable institutions excludes organizations operated principally for the benefit of nonresidents. Pp. 571-595. (a) Because the Government lacked power to regulate interstate commerce during the Nation's first years, the States freely adopted measures fostering local interests without regard to possible prejudice to nonresidents, resulting in a "conflict of commercial regulations, destructive to the harmony of the States." Gibbons v. Ogden, 9 Wheat. 1, 224 (Johnson, J., concurring in judgment). Arguably, this was the cause of the Constitutional Convention. Ibid. The Commerce Clause not only granted Congress express authority to override restrictive and conflicting state commercial regulations, but also effected a curtailment of state power even absent congressional legislation. Pp. 571-572. (b) The Court is unpersuaded by the Town's arguments that the dormant Commerce Clause is inapplicable here, either because campers are
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