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A. 1. a.(1)(a) i) a) I A 1 a (1)(a) i) a)@@2=YGToTHHVXBQck QuoteSingle spaced indented quote - Circv C   (  Cd  ( ( ( FTNFormats for each footnote,  X` hp x (#%'0*,.8135@8: the ImportExport Clause only prohibits States from  J levying duties and imposts. See International  J Business Machines, 517 U.S., at ___ (slip op., at 14!15).  The Maine property tax at issue here is almost certainly not an impost, for, as 18thcentury usage of the  Jv word indicates, an impost was a tax levied on goods at  JN the time of importation. See, e.g., The Observer No. XII, The Connecticut Courant and Weekly Intelligencer, Jan. 7, 1790, p. 1, col. 2 ( [I]mpost is a tax on merchan J dize, payable at the port of entry);% uB> ԍSee also Providence Gazette and Country Journal, Feb. 13, 1790,p.1, col. 1 (reprinting same); Gazette of the United States, Jan. 9, 1790,p. 2, col. 1 (same). N. Bailey, An Universal Etymological English Dictionary (26 ed. 1789) (defining impost as a tax or tribute, but more especially such as is received by a prince or state, for goods  J6 brought into any haven from other nations);6 uB ԍSee also T. Sheridan, A Complete Dictionary of the English Language(6th ed. 1796) ( Impost ... A tax; a toll; custom paid); S. Johnson,A Dictionary of the English Language (7th ed. 1785) ( Im uB post.A tax; a toll; a custom paid. Taxes and imposts upon merchants"## doseldom good to the king's revenue; for that that he wins in the hundred, he loseth in the shire. Bacon's Essays); Barclay's Universal English Dictionary 471 (B. Woodward rev. 1782) ( Impost. A toll; custompaid for goods or merchandise); T. Blount, A LawDictionary (1670) ( Impost Tribute, Tallage, or Custom; but more particularly it is that Tax which the King receives for such merchandises as are importedinto any Haven, from other Nations.... And it may be distin uB guished from Custom, which is rather that profit which the King raisesfrom Wares exported; but they are sometimes confounded); cf. 7Oxford English Dictionary 733 (2d ed. 1989) ( impost ... A tax,  uB duty,imposition, tribute; spec. a customsduty levied on merchandise.  uBm Now chiefly Hist). Miche6$ "  Ԯ J lin, supra, at 287 ( [I]mposts and duties ... are essentially taxes on the commercial privilege of bringing goods  J into a country). Because the tax at issue here is levied on real property"property that cannot possibly have been imported"the tax would not seem to fit within any of the commonly accepted definitions of impost.   Duty, however, though frequently used like impost to denote money paid for custom of goods, An Univer J sal Etymological English Dictionary, supra, does not appear to have been limited to taxes assessed at  Jp portside. See, e.g., S. Johnson, A Dictionary of the English Language (7th ed. 1785) ( Duty ... Tax; impost; custom; toll. All the wines make their way through  J several duties and taxes, before they reach the port) (second emphasis added); 2 Elliot 331 (John Williams, New York ratifying convention) (noting that Congress' Art. I, 8 power extend[s] to duties on all kinds of goods, to tonnage and poundage of vessels, to duties on written instruments, newspapers, almanacs, &c). In fact, imposts seems to have been viewed as a particular subclass of duties; the fact that the two words are used disjunctively in the ImportExport Clause suggests, therefore, that something broader than portside customs was within the constitutional prohibition.  Because of the somewhat ambiguous usage of the@ $ "   words duty and impost, Luther Martin inquired of their meaning during the Convention. James Wilson, a member of the Committee on Detail, replied as follows:  J  [D]uties are applicable to many objects to which the  J` word imposts does not relate. The latter are appropriated to commerce; the former extend to a variety of objects, as stamp duties &c. 2 Farrand 305 (emphasis in original); see also 2 Storing 54 (Luther Martin, in Maryland Convention, describing same colloquy); The Fallacies of the Freeman Detected by a Farmer, Freeman's Journal, April 1788, in 3 Storing 186!187 ( Under the term duties [in Art. I, 8], every species of indirect taxes is included, but it especially means the power of levying money upon printed books, and written instruments). What seems likely from these descriptions is that a duty, though broader than an impost, was still a  J tax on particular goods or written instruments.  It is important to note, moreover, that the MartinWilson colloquy is in reference to the Art. I, 8 power given to Congress to levy duties. That power is broader than the prohibition on States found in Art. I, 10, which reaches not all duties, but only those on imports  J or exports.q  uB ԍSee, e.g., DeWitt, Letter To the Free Citizens of the Commonwealthof Massachusetts, American Herald, Boston, Oct.Dec. 1787, in  uBf 4Storing 23 (noting that Congress shall have the exclusive power of imposts and the duties on imports and exports, [and, implicitly, a concurrent] power of laying excises and other duties) (emphasis added);Letters from The Federal Farmer, Oct. 10, 1787, in 2 Storing 239(distinguishing between impost duties, which are laid on imported goods [and] may usually be collected in a few seaport towns, and internal taxes, [such] as poll and land taxes, excises, duties on all written instruments, etc. [which] may fix themselves on every person andspecies of property in the community); Essays of Brutus, Dec. 13, 1787 in 2 Storing 392!393 (same); see also 2 Farrand 589 (noting that Morris did not consider the dollar per Hhd laid on Tobo. in Virga. as aduty on exportation, as no drawback would be allowed on Tobo.C"## takenout of the Warehouse for internal consumption).q But even without this additional limita!G"  Ԯ J tion, one kind of tax that duties almost certainly did not  J encompass were direct taxes, such as property taxes  J and poll taxes. See, e.g., The Federalist No. 12 (A. Hamilton) (distinguishing direct taxes, such as property taxes, from indirect taxes, such as imposts, duties, and  J8 excises); Freeman's Journal, in 3 Storing, supra, 186!187 ( Under the term duties [in Art. I, 8], every species of  J indirect taxes is included); see also Michelin, 423 U.S., at 286, 290!291.  The tax at issue here is nothing more than a tax on real property. Such taxes were classified as direct taxes at the time of the Framing, and were not within the class of indirect taxes encompassed by the common understanding of the word duties. The amount of the Maine tax is tied to the value of the real property on which it is imposed, not to any particular goods, and not even to the number of campers served. It does not appear, therefore, to be a duty on imports in any  J0 sense of the words.' 0G uBO ԍEven were I to agree with the majority that a particular property  uB taxmay be a property tax in name only, see ante, at 9!10, and even wereI to assume that travel across state lines to consume services in another State renders those traveling consumers imports, it is difficultto characterize the tax at issue here as a duty on imports. It  uB is,rather, as the majority recognizes, a generally applicable state  uB property tax. Ante, at 1. Maine's grant of an exemption from the tax to some charitable organizations that dispense their charity primarily toMaine residents makes the tax something less than universal, but itdoes not make the tax, even in practical effect, one that is levied  uBu exclusively, or even primarily, on imports. See, e.g., New Energy Co.  uB, ofInd. v. Limbach, 486 U.S. 269 (1988); Maryland v. Louisiana, 451  uB U.S. 725, 756 (1981); License Cases, 5 How. 504, 576 (1847); cf. Davis  uB v.Michigan Dept. of Treasury, 489 U.S. 803, 821 (1989) (Stevens, J., dissenting) (arguing, in an analogous context, that the fact that a Statemay elect to grant a preference, or an exemption, to a small percentage of its residents does not make the tax discriminatory). Even when coupled with the tax "n"  Ԍexemption for certain Maine charities (which is, in truth, no different than a subsidy paid out of the State's general revenues), Maine's property tax would not seem to be a Duty or Impost on Imports or Exports within the meaning of the ImportExport Clause. Thus, were  J8 we to overrule Woodruff and apply the ImportExport Clause to this case, I would in all likelihood sustain this tax under that Clause as well.