In this article, we will explore the fascinating world of Polar Tankers, Inc. v. City of Valdez, a topic that has captured the attention of individuals of all ages and backgrounds. From its impact on modern society to its historical relevance, Polar Tankers, Inc. v. City of Valdez has been the subject of interest and debate in various spheres. Through this exhaustive analysis, we will take a look at the many facets that make Polar Tankers, Inc. v. City of Valdez a topic of great importance in the current context. We will address its origins, evolution and possible future developments, in order to provide a comprehensive and enriching vision of Polar Tankers, Inc. v. City of Valdez. Join us on this journey through a topic that never ceases to surprise and captivate!
The City of Valdez in Alaska imposed a property tax that, in practice, applied only to large oil tankers. Polar Tankers, a ConocoPhillips subsidiary, sued, arguing that the tax violated the Tonnage Clause of the Constitution, which forbids a state, "without the Consent of Congress, lay any Duty of Tonnage."
The Supreme Court agreed with Polar Tankers. The court noted that the original meaning of the clause was as a term of art for a tax imposed that varies with "the internal cubic capacity of a vessel," but emphasized that a consistent line of cases had read the clause broadly, "forbidding a State to do that indirectly which she is forbidden ... to do directly."[1] Those cases, the court concluded, stood for the proposition that the tonnage clause's prohibition reaches any taxes or duties on a ship, "whether a fixed sum upon its whole tonnage, or a sum to be ascertained by comparing the amount of tonnage with the rate of duty ... regardless of name or form ... which operate to impose a charge for the privilege of entering, trading in, or lying in a port."[2]
With this premise in mind, the court concluded that because Valdez taxes "ships and to no other property at all ... in order to obtain revenue for general city purposes ... the kind of tax that the Tonnage Clause forbids Valdez to impose without the consent of Congress, consent that Valdez lacks."
^Id. at _ (internal quotation marks omitted) (quoting Steamship Co. v. Portwardens, 73U.S. (6 Wall.) 31, 35 (1867) and Clyde Mallory Lines v. Alabama ex rel. State Docks Comm'n, 296U.S.261, 265-56 (1935)).
