574
Opinion of the Court
(quoting United States v. Women's Sportswear Mfrs. Assn., 336 U. S. 460, 464 (1949)).
Although Heart of Atlanta involved Congress' affirmative Commerce Clause powers, its reasoning is applicable here. As we stated in Hughes v. Oklahoma, 441 U. S. 322 (1979): "The definition of 'commerce' is the same when relied on to strike down or restrict state legislation as when relied on to support some exertion of federal control or regulation." Id., at 326, n. 2. That case in turn rested upon our reasoning in Philadelphia v. New Jersey, 437 U. S. 617 (1978), in which we rejected a "two-tiered definition of commerce." Id., at 622. "Just as Congress ha[d] power to regulate the interstate movement of [the] wastes" at issue in that case, so too we held were States "not free from constitutional scrutiny when they restrict that movement." Id., at 622-623. See also Sporhase v. Nebraska ex rel. Douglas, 458 U. S. 941, 953 (1982).
The Town's arguments that the dormant Commerce Clause is inapplicable to petitioner because the campers are not "articles of commerce," or more generally that interstate commerce is not at issue here, are therefore unpersuasive. The services that petitioner provides to its principally out-of-state campers clearly have a substantial effect on commerce, as do state restrictions on making those services available to nonresidents. Cf. C & A Carbone, Inc. v. Clarkstown, 511 U. S. 383, 391 (1994).
The Town also argues that the dormant Commerce Clause
is inapplicable because a real estate tax is at issue. We disagree. A tax on real estate, like any other tax, may impermissibly burden interstate commerce. We may assume as the Town argues (though the question is not before us) that Congress could not impose a national real estate tax. It does not follow that the States may impose real estate taxes in a manner that discriminates against interstate commerce. A State's "power to lay and collect taxes, comprehensive and necessary as that power is, cannot be exerted in a way which
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