Quill Corp. vs. North Dakota

Respondent North Dakota, through its Tax Commissioner, filed an action in state court to require petitioner Quill Corporation--an out-of-state mail-order house with neither outlets nor sales respesentatives in the State--to collect and pay a use tax on goods purchased for use in the State. The trail court ruled in Quill's favor. It found the case indistinguishable from National Bellas Hess, Inc. v. Department of Revenue of Ill., 386 U.S. 753, which, in holding that a similar Illinois statute violated the Fourteenth Amendment's Due Process Clause and created an unconstitutional burden on interstate commerce, concluded that a "seller whose only connection with customers in the State is by common carrier or the...mail" lacked the requisite minimum contacts with the State.