Stanley Forman Reed

“ An interpretation of the privileges and immunities clause which restricts the power of the states to manage their own fiscal affairs is a matter of gravest concern to them. [23] It is only the emphatic requirements of the Constitution which properly may lead the federal courts to such a conclusion.
Appellant relies upon Colgate v. Harvey, supra, [24] as a precedent to support his argument that the present statute is not within the limits of permissible classification and violates the privileges and immunities clause. ”

“ The executor used as one defense against this claim the contention that a tax on deposits in banks outside of Kentucky at a higher rate than the tax upon bank deposits within Kentucky would abridge decedent's privileges and immunities as a citizen of the United States, deprive him of his property right and the liberty to keep money on deposit outside of Kentucky without due process of law, and deny to him equal protection of the law in violation of the Fourteenth Amendment. ”

“ Since the members of a legislature necessarily enjoy a familiarity with local conditions which this Court cannot have, the presumption of constitutionality can be overcome only by the most explicit demonstration that a classification is a hostile and oppressive discrimination against particular persons and classes. ”