Alico, LLC v. Somers

Summary

The court held that Connecticut's motor vehicle property tax, which applies based on where a vehicle most frequently leaves from and returns to, does not violate the dormant Commerce Clause. Applying the framework for facially neutral state taxes, the court concluded that the tax is fairly apportioned because identical enactments in every state would tax a vehicle in only one state. Any double taxation resulted from the interaction of Connecticut's location-based tax and Massachusetts' registration-based tax, not from discriminatory features of Connecticut's statute.