dormant commerce clause (South Carolina) · Go Syfert
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dormant commerce clause in South Carolina

5 South Carolina opinions name it 2 courts 2011–2026 2 in the last five years

The cases below were cited by South Carolina courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (6)

CaseFollowedCited
Colon Health Centers of America, LLC v. Hazelgreen
ca4 · 2013 · cited in 2 South Carolina opinions naming this issue, 2017–2018
2 sentences

2018In order to prove discriminatory effect, the party asserting a Dormant Commerce Clause violation must show that the state law, "if enforced, would negatively impact interstate commerce to a greater degree than intrastate commerce." Hazel II , 813 F.3d at 153 (quoting Hazel I , 733 F.3d at 543 ).

2018In order to prove discriminatory effect, the party asserting a Dormant Commerce Clause violation must show that the state law, "if enforced, would negatively impact interstate commerce to a greater degree than intrastate commerce." Hazel II , 813 F.3d at 153 (quoting Hazel I , 733 F.3d at 543 ).

22
South Dakota v. Wayfair, Inc.green
scotus · 2018 · cited in 1 South Carolina opinions naming this issue, 2026–2026
2 sentences

2026Ed. 2d 91, 110 (1992) (holding the dormant commerce clause requires a business have a physical presence in a state to be subject to the state's sales tax laws), overruled by S. Dakota v. Wayfair, Inc., 585 U.S. 162, 188 , 138 S. Ct. 2080, 2099 , 201 L.

2026Ed. 2d 91, 110 (1992) (holding the dormant commerce clause requires a business have a physical presence in a state to be subject to the state's sales tax laws), overruled by S. Dakota v. Wayfair, Inc., 585 U.S. 162, 188 , 138 S. Ct. 2080, 2099 , 201 L.

11
National Bellas Hess, Inc. v. Department of Revenuegreen
scotus · 1967 · cited in 1 South Carolina opinions naming this issue, 2024–2024
1 sentence

2024See Nat'l Bellas Hess, Inc. v. Dep't of Revenue of the State of Ill., 386 U.S. 753 (1967) (suggesting a business was required to have a physical presence in the taxing state to form the requisite nexus to the state); Quill Corp. v. North Dakota, 504 U.S. 298 (1992) (requiring, pursuant to the dormant commerce clause, a physical presence for a 1 S.C.

11
Colon Health Centers of America, LLC v. Hazelgreen
ca4 · 2016 · cited in 1 South Carolina opinions naming this issue, 2018–2018
2 sentences

2018In order to prove discriminatory effect, the party asserting a Dormant Commerce Clause violation must show that the state law, "if enforced, would negatively impact interstate commerce to a greater degree than intrastate commerce." Hazel II , 813 F.3d at 153 (quoting Hazel I , 733 F.3d at 543 ).

2018In order to prove discriminatory effect, the party asserting a Dormant Commerce Clause violation must show that the state law, "if enforced, would negatively impact interstate commerce to a greater degree than intrastate commerce." Hazel II , 813 F.3d at 153 (quoting Hazel I , 733 F.3d at 543 ).

11
Lenscrafters, Inc. v. Robinsongreen
ca6 · 2005 · cited in 1 South Carolina opinions naming this issue, 2018–2018
2 sentences

2018See id. at 157 (holding that those asserting a Dormant Commerce Clause violation " 'bear[ ] the burden of proving that the burdens placed on interstate commerce outweigh' [a law's] local benefits." (quoting LensCrafters, Inc. v. Robinson , 403 F.3d 798 , 805 (6th Cir. 2005) ) ).

2018See id. at 157 (holding that those asserting a Dormant Commerce Clause violation " 'bear[ ] the burden of proving that the burdens placed on interstate commerce outweigh' [a law's] local benefits." (quoting LensCrafters, Inc. v. Robinson , 403 F.3d 798 , 805 (6th Cir. 2005) ) ).

11
Travelscape, LLC v. South Carolina Department of Revenuegreen
sc · 2011 · cited in 1 South Carolina opinions naming this issue, 2017–2017
2 sentences

2017See Colon Health Ctrs. of Am., LLC v. Hazel, 733 F.3d 535, 546 (4th Cir. 2013) (stating the two tests for determining a violation of the Dormant Commerce Clause are both "fact-bound"); Travelscape, 391 S.C. at 109 , 705 S.E.2d at 38 (referring to an "as-applied" constitutional challenge to a statute or regulation as an "inherently factual issue"); id. at 109 , 705 S.E.2d at 39 (stating the ALC is "better suited for making the factual determinations necessary for an as applied challenge, and finding a statute or regulation unconstitutional as applied to a specific party does not affect the faci

2017See Colon Health Ctrs. of Am., LLC v. Hazel, 733 F.3d 535, 546 (4th Cir. 2013) (stating the two tests for determining a violation of the Dormant Commerce Clause are both "fact-bound"); Travelscape, 391 S.C. at 109 , 705 S.E.2d at 38 (referring to an "as-applied" constitutional challenge to a statute or regulation as an "inherently factual issue"); id. at 109 , 705 S.E.2d at 39 (stating the ALC is "better suited for making the factual determinations necessary for an as applied challenge, and finding a statute or regulation unconstitutional as applied to a specific party does not affect the faci

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in South Carolina. Read the followed side critically anyway.

Also cited on this issue (2)

CaseCitedYears
Quill Corp. v. North Dakota Ex Rel. Heitkamp red
scotus · 1992
2 sentences

2024See Nat'l Bellas Hess, Inc. v. Dep't of Revenue of the State of Ill., 386 U.S. 753 (1967) (suggesting a business was required to have a physical presence in the taxing state to form the requisite nexus to the state); Quill Corp. v. North Dakota, 504 U.S. 298 (1992) (requiring, pursuant to the dormant commerce clause, a physical presence for a 1 S.C.

2011A state tax withstands a Dormant Commerce Clause challenge so long as the tax (1) "`is applied to an activity with a substantial nexus with the taxing State, (2) is fairly apportioned, (3) does not discriminate against interstate commerce, and (4) is fairly related to the services provided by the State.'" Quill, 504 U.S. at 311 , 112 S.Ct. at 1912 (quoting Complete Auto, 430 U.S. at 279 , 97 S.Ct. at 1079 ).

22011–2024
Complete Auto Transit, Inc. v. Brady green
scotus · 1977
2 sentences

2011A state tax withstands a Dormant Commerce Clause challenge so long as the tax (1) "`is applied to an activity with a substantial nexus with the taxing State, (2) is fairly apportioned, (3) does not discriminate against interstate commerce, and (4) is fairly related to the services provided by the State.'" Quill, 504 U.S. at 311 , 112 S.Ct. at 1912 (quoting Complete Auto, 430 U.S. at 279 , 97 S.Ct. at 1079 ).

2011A state tax withstands a Dormant Commerce Clause challenge so long as the tax (1) "`is applied to an activity with a substantial nexus with the taxing State, (2) is fairly apportioned, (3) does not discriminate against interstate commerce, and (4) is fairly related to the services provided by the State.'" Quill, 504 U.S. at 311 , 112 S.Ct. at 1912 (quoting Complete Auto, 430 U.S. at 279 , 97 S.Ct. at 1079 ).

12011–2011

Statutes the citing opinions construe

SC § S.C. Code Ann. § 12-36-20 (3) SC § S.C. Code Ann. § 12-36-70 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

WA 32 (1999–2025) CA 32 (1992–2025) IL 15 (1996–2024) MA 14 (1998–2023) PA 11 (1996–2023) NJ 9 (1987–2021) OH 7 (2000–2024) TX 6 (2008–2023) SC 5 (2011–2026) FL 5 (2004–2014) NY 5 (1998–2023) MD 4 (1984–2021) HI 4 (2013–2022) DC 4 (2006–2023) IA 4 (2010–2015) NV 3 (2014–2017) CT 3 (2016–2023) PR 3 (2007–2012) AR 3 (1995–2007) NE 3 (1990–2005) CO 3 (2011–2018) AL 3 (1998–2025) OK 2 (2014–2014) MN 2 (1997–1997) IN 2 (1995–2023) NH 2 (2014–2015) SD 2 (1997–1997) OR 2 (2015–2018) WI 2 (2005–2023) AK 2 (2022–2025)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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