stylistic:tone
Applicability to interstate commerce

The court reasoned that "the words imports, exports, and imposts are used with exclusive reference to foreign trade" in Article VI, §3 and Article IX, §1 of the Articles of Confederation and found that the records of the Constitutional Convention used the words "duty," "impost," and "import" in reference to foreign trade. The court's final line of reasoning was that application of the Import-Export Clause to interstate commerce would produce "the grossest injustice" and that the "equality of public burdens in all our large cities impossible," because contemporary case law prohibited the taxation of imports. "The merchant of Chicago who buys his goods in New York and sells at wholesale in the original packages, may have his millions employed in trade for half a lifetime and escape all State, county, and city taxes; for all that he is worth is invested in goods which he claims to be protected as imports from New York."