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01-270 YELLOW TRANSPORTATION, INC. v. MICHIGAN Ruling below: Michigan Supreme Court, 627 N.W.2d 236. QUESTION PRESENTED Congress in 1991 directed the Interstate Commerce Commission ("ICC") to prescribe new and more simplified standards under which states are permitted to charge fees for registration of interstate motor carrier operations. 49 U.S.C. § 11506( c )( 1) It specified that these new standards "shall establish a fee system" that "will result in a fee for each participating State that is equal to the fee *** that such State collected or charged as of November 15, 1991". 49 U.S.C. §11506(c)(2)(B)(iv)(I11) In issuing these standards, the ICC specifically ruled that states must apply reduced fee levels based on so-called reciprocity arrangements between states in determining the November 15, 1991 fee level. The D.C. Circuit held on appeal that "the [ICC] was correct in concluding that the plain language of the statute precludes" allowing states to charge fees higher than those in place under reciprocity arrangements. Under reciprocity arrangements in place on November 15, 1991, Michigan had reduced its registration fee for vehicles plated in Illinois from $10 per vehicle to zero. Expressly disregarding the ICC, a divided Michigan Supreme Court deemed Michigan's reciprocity arrangement with Illinois to be "irrelevant" to the determination of the fee collected or charged on November 15, 1991, and accordingly rejected petitioner's challenge to assessment of a $10 per vehicle fee for Illinois-plated vehicles. The question presented is whether the Michigan Supreme Court erred in disregarding the ICC's determination and ruling that, notwithstanding 49 U.S.C. §11506(c)(2)-(B)(iv)(I11), States may charge registration fees in excess of those charged and collected under reciprocity arrangements in force as of November 15, 1991. CERT. GRANTED: 1/22/02 Limited to the following question: Whether the Michigan Supreme Court erred in holding that, under 49 U.S.C. 11506(c)(2)(B)(iv)(III) (1994) and 14504(c)(2)(B)(iv)(III) (Supp. V 1999), only state's "generic" fee is relevant to determining fee that was "collected or charged as of November 15, 1991"?
In the case of Yellow Transportation, Inc. v. Michigan et al., 2002, the U.S Supreme Court was asked to determine whether a state could impose fees on trucks engaged in interstate commerce without violating federal law. The dispute arose when Michigan imposed fees on all commercial vehicles operating within its borders, including those involved in interstate trade like Yellow Transportation Inc., an Illinois-based company that operated across several states. The company argued that these charges were discriminatory and violated the Commerce Clause of the U.S Constitution which prohibits states from passing laws that unduly burden or discriminate against interstate commerce. The court ruled unanimously in favor of Michigan, holding that such fees did not violate federal law as long as they were applied equally to both intrastate and interstate carriers and used for highway maintenance purposes benefiting all users. It concluded that while Congress had power over interstate commerce under the Commerce Clause, it had not exercised this authority to prevent states from imposing reasonable user fees on commercial vehicles using their highways.
The dissenting opinion in the case of Yellow Transportation, Inc. v. Michigan argued that the majority's decision to strike down Michigan's tax on interstate motor carriers was incorrect because it violated principles of federalism and state sovereignty. The dissenters believed that states should have the right to impose taxes on businesses operating within their borders as a means of raising revenue for public services, even if those businesses also operate in other states. They contended that such taxation does not discriminate against interstate commerce or unduly burden it, but rather treats all businesses equally regardless of where they are based or how much business they do in a particular state. Furthermore, they pointed out that Congress has expressly allowed states to levy these types of taxes under certain conditions through its enactment of the Interstate Commerce Act and subsequent amendments thereto.