Park McLain, Inc. v. Hoey
District Court, E.D. North Carolina · 1937-07-19 · cited 8×
This case involved a challenge by North Carolina dealers of used cars imported from other states to a 1937 state statute that required them to register such vehicles, post a bond covering title defects or fraud, and pay a $10 fee per bond before sale, with penalties for noncompliance; no such requirements applied to sales of used cars sourced within the state. The plaintiffs sought to enjoin enforcement of the bond and fee provisions, arguing they violated the Commerce Clause. The court held that the bond and fee requirements were invalid as applied to the plaintiffs, who were in-state businesses with permanent locations. The core reasoning was that states may not discriminate against goods originating in other states by imposing burdens not placed on local goods, as this directly burdens interstate commerce in violation of the Commerce Clause, even if the measure aims to prevent fraud; any needed regulation of interstate sales must come from Congress rather than discriminatory state legislation.