Complete Auto Four-Prong Test Overruled Precedent

doctrine of stare decisis loses its practical significance. Stare decisis should never be “a mechanical formula of adherence to the latest decision,” but rather a guide when circumstances have not warranted a change. In a Quill concurring opinion, Justices Antonin Scalia, Anthony Kennedy, and Clarence Thomas stated that while they supported the conclusion to overrule the due process conclusion of National Bellas Hess, they would reaffirm the Commerce Clause aspect of the physical presence test solely because of stare decisis. However, there is a standard for overturning prior precedent—looking at “factual, cultural, and economic changes, reliance interests, and the change in the legal environment.” While there is not a precise line that must be reached in order to automatically trigger the Court to overturn stare decisis, the problems that exist with an archaic rule will keep progressing until a new solution is formulated. …show more content…
For example, the Complete Auto four-prong test overruled precedent from Spector Motor Service v. O’Connor. The Spector Court held that a state could not apply a tax directly on the privilege of doing business in a state. In Complete Auto, the Supreme Court held that the Spector rule was overly formulistic because it simply looked to see if the text of a statute contained “privilege of doing business” and ignored any practical effect the tax may have. Likewise, the Supreme Court stated that time had stripped the Spector rule of its meaning and any practical significance because it forced courts to ignore “whether the challenged tax produced results forbidden by the Commerce Clause.” In the same way the Spector rule became obsolete, Quill’s physical presence rule is continuing along the same