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The U.S. Supreme Court case American Steel Foundries v. Robertson, Commissioner, et al., 1925 revolved around the issue of whether a state could impose taxes on an out-of-state corporation for its in-state operations without violating the Due Process Clause of the Fourteenth Amendment. The plaintiff was American Steel Foundries (ASF), an Illinois-based company that had manufacturing plants in several states including Indiana where it also owned property and employed workers. ASF argued that Indiana's tax assessment violated their constitutional rights as it included income from interstate commerce activities which were beyond the state's jurisdiction. However, the court ruled against ASF stating that while a state cannot directly tax interstate commerce or discriminate against it, they can levy taxes on net income derived from such commerce if there is sufficient connection between the business conducted within its borders and profits made by said business. In this case, since ASF maintained substantial operations in Indiana contributing to their overall profit-making capacity - owning real estate and employing local labor - taxing them did not violate due process rights under Fourteenth Amendment.
In the dissenting opinion for American Steel Foundries v. Robertson, Justice McReynolds disagreed with the majority's interpretation of the Longshoremen's and Harbor Workers' Compensation Act. He argued that it was not Congress' intention to provide compensation for injuries sustained while traveling to or from work, as such risks are common to all persons regardless of their employment. Furthermore, he contended that if Congress had intended this broad coverage, they would have explicitly stated so in clear language within the act itself. The justice believed that by extending coverage beyond what is specified in law based on a general principle of employee protection could lead to arbitrary decisions and uncertainty about what is covered under workers’ compensation laws.