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8 Oregon opinions name it 1 courts 2006–2025 5 in the last five years
The cases below were cited by Oregon 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.
| Case | Followed | Cited |
|---|---|---|
Commonwealth Edison Co. v. Montanagreen2 sentences2018Under that test, “the measure of the tax must be reasonably related to the extent of the contact, since it is the activities or presence of the taxpayer in the State that may properly be made to bear a just share of state tax burden.” Commonwealth Edison Co. v. Montana, 453 US 609, 626 , 101 S Ct 2946 , 69 L Ed 2d 884 (1981) (emphasis in original; internal quotation marks omitted). 2006See id. at 645 (Blaekmun, J., dissenting) (arguing that the Court had “emasculatefd]” the fair relationship prong of the Complete Auto test). 11 The property factor in the traditional three-factor formula is typically measured by the cost of property and only includes real and tangible personal property. | 1 | 2 |
South Dakota v. Wayfair, Inc.green2 sentences2025The South Dakota law at issue in Wayfair was triggered by a business having $100,000 in sales or 200 or more separate transactions. 585 US at 188 . 2025In overruling the physical presence requirement, the court explained that the substantial nexus prong of the Complete Auto test is satisfied “when the taxpayer [or collector] ‘avails itself of the substantial privilege of carrying on business’ in that jurisdiction.” Id. at 188 (citation omitted). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Oregon. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Barclays Bank PLC v. Franchise Tax Bd. of Cal.
green
2 sentences2025Foreign Commerce Clause In Barclays, 512 US at 311 , the United States Supreme Court declared: “A tax affecting foreign commerce therefore raises two concerns in addition to the four delineated in Complete Auto. 2025Foreign Commerce Clause In Barclays, 512 US at 311 , the United States Supreme Court declared: “A tax affecting foreign commerce therefore raises two concerns in addition to the four delineated in Complete Auto. | 3 | 2024–2025 |
Quill Corp. v. North Dakota Ex Rel. Heitkamp
red
2 sentences2018In both Bellas Hess and Quill, the court took note that “many variations in rates of tax, in allowable exemptions, and in administrative and record-keeping requirements” across thousands of jurisdictions “could entangle a mail-order house in a virtual welter of complicated obligations.” Id. at 313 n 6 (quoting Bellas Hess, 368 US at 759-60) (brackets and internal quotation marks omitted). 2018Undue burden In Quill, the Court explained that substantial nexus and “fairly related” prongs of the Complete Auto test “ensure that state taxation does not unduly burden interstate commerce.” Quill, 504 US at 313 . | 2 | 2006–2018 |
Complete Auto Transit, Inc. v. Brady
green
2 sentences2018Fairly Related Under the fourth prong of the Complete Auto test, nexus with out-of-state taxpayers requires that a tax be “fairly related to the services provided by the State.” 430 US at 279 . 2006It also appears to be embodied in the fourth prong of the Complete Auto test, rooted in the Commerce Clause, which requires that a tax be “fairly related to the services provided by the State.” 430 US at 279 . | 2 | 2006–2018 |
Pike v. Bruce Church, Inc.
green
2 sentences2021Balancing test under Pike v. Bruce Church, Inc. The Court in Wayfair suggested that the “balancing framework” of Pike v. Bruce Church, Inc., 397 US 137 , 90 S Ct 844 , 25 L Ed 2d 174 (1970), may be relevant in determining whether the Commerce Clause forbids imposition of a particular state tax. 2021Balancing test under Pike v. Bruce Church, Inc. The Court in Wayfair suggested that the “balancing framework” of Pike v. Bruce Church, Inc., 397 US 137 , 90 S Ct 844 , 25 L Ed 2d 174 (1970), may be relevant in determining whether the Commerce Clause forbids imposition of a particular state tax. | 1 | 2021–2021 |
Goldberg v. Sweet
green
2 sentences2020Illinois telephone consumers also subscribe to telephone service in Illinois, own or rent telephone equipment at an Illinois service address, and receive police and fire protection as well as the other general services provided by the State of Illinois.” Goldberg v. Sweet, 488 US 252, 267 , 109 S Ct 582 , 102 L Ed 607 (1989) (internal quotation marks omitted; citations omitted; emphasis in original). benefit they are imposed.” Id. at 717. 2020Illinois telephone consumers also subscribe to telephone service in Illinois, own or rent telephone equipment at an Illinois service address, and receive police and fire protection as well as the other general services provided by the State of Illinois.” Goldberg v. Sweet, 488 US 252, 267 , 109 S Ct 582 , 102 L Ed 607 (1989) (internal quotation marks omitted; citations omitted; emphasis in original). benefit they are imposed.” Id. at 717. | 1 | 2020–2020 |
National Bellas Hess, Inc. v. Department of Revenue
red
2 sentences2020Substantial nexus The Court in Wayfair recently reexamined the substantial nexus requirement, overruling the Court’s decisions in Quill and National Bellas Hess v. Illinois, 386 US 753, 758-59 , 87 S Ct 1389 , 18 L Ed 2d 505 (1967) (Bellas Hess), which had established and maintained a requirement that 21 The department notes that Congress has “specifically affirmed” the power of states to impose 9-1-1 taxes on VoIP providers. 2020Substantial nexus The Court in Wayfair recently reexamined the substantial nexus requirement, overruling the Court’s decisions in Quill and National Bellas Hess v. Illinois, 386 US 753, 758-59 , 87 S Ct 1389 , 18 L Ed 2d 505 (1967) (Bellas Hess), which had established and maintained a requirement that 21 The department notes that Congress has “specifically affirmed” the power of states to impose 9-1-1 taxes on VoIP providers. | 1 | 2020–2020 |
American Trucking Associations, Inc. v. State
green
2 sentences2018In American Trucking Associations, Inc. v. State of Oregon, 339 Or 554, 563-67 , 124 P3d 1210 (2005), the Oregon Supreme Court concluded that the Complete Auto test—and not the Evansville-Vanderburgh test—was appropriate for analyzing a “flat-fee” highway tax. 2018In American Trucking Associations, Inc. v. State of Oregon, 339 Or 554, 563-67 , 124 P3d 1210 (2005), the Oregon Supreme Court concluded that the Complete Auto test—and not the Evansville-Vanderburgh test—was appropriate for analyzing a “flat-fee” highway tax. | 1 | 2018–2018 |
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.
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.