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The U.S. Supreme Court case Trinityfarm Construction Co. v. Grosjean, Supervisor of Public Accounts of Louisiana in 1933 revolved around a dispute over taxation on interstate commerce activities by the state of Louisiana. The plaintiff, Trinityfarm Construction Company, was an Illinois-based corporation that had been contracted to construct federal buildings in New Orleans and Shreveport, Louisiana. The company purchased materials from out-of-state suppliers which were then shipped directly to the construction sites for use without being stored or used within the state prior to their incorporation into the buildings under construction. Louisiana's tax assessor imposed a "use" tax on these materials arguing they were used within its jurisdiction while constructing federal buildings; however, this action was contested by Trinityfarm as unconstitutional interference with interstate commerce and infringement upon federal sovereignty. The Supreme Court ruled in favor of Trinityfarm stating that such taxes could not be levied against goods brought into a state solely for use in fulfilling contracts with the United States government because it would interfere with Federal functions and violate principles related to intergovernmental immunity from taxation.
In the dissenting opinion for Trinityfarm Construction Co. v. Grosjean, Justice Cardozo disagreed with the majority's decision that Louisiana's tax on interstate transportation of natural gas was unconstitutional. He argued that this case did not involve a direct burden on interstate commerce but rather an indirect one, which states have been allowed to impose in previous cases as long as they were non-discriminatory and fairly apportioned. According to him, Louisiana’s tax met these criteria because it applied equally to all companies transporting natural gas within its borders regardless of whether their operations were intrastate or interstate. Furthermore, he contended that the state had a legitimate interest in taxing such activities due to their extensive use of local resources and infrastructure like roads and bridges. Therefore, he believed that striking down this tax would undermine states' ability to raise revenue from businesses operating within their jurisdiction while benefiting from public services funded by taxpayers.