Walgreens Specialty Pharmacy, LLC v. Commissioner of Revenue, Relator.

Summary

The court reversed the Minnesota Tax Court and held that Minnesota's Legend Drug Tax applies to an out-of-state pharmacy that receives drugs for resale or use in Minnesota and delivers them to Minnesota customers through a common carrier. The court further held that applying the tax to Walgreens Specialty Pharmacy's transactions satisfies both the Due Process Clause and the Commerce Clause because the pharmacy purposefully directed its activities toward Minnesota and the tax is internally consistent. Justices Anderson and Gildea dissented, arguing that the statute's plain language taxes only deliveries made in Minnesota by the pharmacy itself and therefore does not reach common-carrier deliveries.