stylistic:style_transfer
Michelin Tire Corp. v. Wages

In 1976, the U.S. Supreme Court re-examined the original package doctrine and fundamentally changed its Import-Export Clause analysis. The case concerned whether a local ad valorum tax on a business' inventory could be applied to imported tires held in a Michelin warehouse pending distribution to the company's retail outlets. About 75% of the tires had been loaded into truck trailers (known as "sea vans") that were loaded onto ships in France or Nova Scotia, transported to the U.S., then driven to the Georgia warehouse. The remaining 25% were placed on trailers in Nova Scotia, then driven to the Michelin warehouse. In both cases, at the warehouse the tires were unloaded, sorted, and stored until purchased and delivered to a retail store. The ad valorum tax applied to business inventory regardless of whether it was imported or not and was therefore non-discriminatory. The tires were not individually packaged during the importation process. Under the "original package" doctrine, the tires could not be subjected to even non-discriminatory taxes until they lost their character as imports and became incorporated into the general mass of property of the state. Because it was impractical to individually package some items shipped in bulk, the defining time for items shipped in bulk was when they were broken up.