Woodruff v. Parham 8 Wallace 123 (1869)
WOODRUFF v. PARHAM 8 Wallace 123 (1869)
Woodruff produced a retreat from the broad enunciation of the original package doctrine in brown v. maryland (1827). In that case Chief Justice john marshall had said in an obiter dictum that the doctrine applied "equally to importations from a sister State.…" In this case the city of Mobile, Alabama, had taxed various commodities and transactions including goods imported from other states and sold in their original and unbroken packages. Woodruff alleged that this tax violated the constitutional clause forbidding state imposts or duties on imports. The Court ruled unanimously that the clause applied only to goods imported from foreign countries. Because the tax did not discriminate against the products of other states, it did not burden interstate commerce.) In effect, the Court limited the original package doctrine to foreign commerce.
Leonard W. Levy