440
Opinion of the Court
the respondent judges urge, as the Eleventh Circuit ruled, that the Ordinance is invalid under Johnson v. Maryland, 254 U. S. 51, 57 (1920), which held that a State could not require a federal postal employee to obtain a state driver's license before performing his federal duties. See Jefferson County, 92 F. 3d, at 1572-1573. In reading the Ordinance to impose a license requirement resembling the driver's license at issue in Johnson, the judges stress the Ordinance's incautious "unlawful . . . to engage in" language. Those words, however, likely were written with nonfederal employees, the vast majority of the occupational taxpayers, in front view. As earlier observed, see supra, at 439, the actual operation of the Ordinance, i. e., its practical impact, is critical. See Murray Corp., 355 U. S., at 492.
In practice, Jefferson County's license tax serves a revenue-raising, not a regulatory, purpose. Jefferson County neither issues licenses to taxpayers, nor in any way regulates them in the performance of their duties based on their status as licensed taxpayers. Cf. Johnson, 254 U. S., at 57 ("[The state license requirement] lays hold of [Federal Government employees] in their specific attempt to obey [federal] orders and requires qualifications in addition to those that the [Federal] Government has pronounced sufficient."); Leslie Miller, Inc. v. Arkansas, 352 U. S. 187, 189, 190 (1956) (per curiam) (holding that private contractors, seeking to bid on federal contracts, cannot be required first to submit to state licensing procedures that "determin[e]" a contractor's "qualifications"; such state regulation is inconsistent with the governing federal procurement statute and regulations, which provide standards for judging the "responsibility" of competitive bidders (internal quotation marks omitted)). In response to the judges' refusal to pay the tax, Jefferson County has done no more than institute a collection suit. See Jefferson County, 92 F. 3d, at 1565. Alabama, of course, cannot make it unlawful to carry out the
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