Pierce Butler

“ In their argument here, plaintiffs in error stated that skins and hides are not manufactured into finished products in Louisiana, and that all are shipped out of the state. But that is no objection to the tax. The state's power to tax property is not destroyed by the fact that it is intended for and will move in interstate commerce. Such skins and hides may be taxed while in the hands of dealers before they move in interstate commerce. ”

“ The Supreme Court of Louisiana held that the act here in question is a police regulation and not a revenue act; that its object is to conserve and protect all furbearing animals and alligators within its borders, including their skins and hides; that the various subdivisions of the act relate to that object, and that payment of the tax is a condition precedent to the divestiture of the state's title and its transfer to the dealer paying the tax. ”

“ Section 3 levies a severance tax of 2 per cent. on the value of all skins and hides taken from wild fur-bearing animals or alligators within the state, to be paid by the dealer to the state through the department of conservation. By other sections, trappers, buyers and dealers are required to pay license fees and to furnish to the department information concerning their respective occupations; an open season is fixed in each year for the taking of fur-bearing animals and alligators respectively, and such taking is prohibited at other times. ”