Thomas Styczinski v. Grace Arnold

Summary

The Eighth Circuit held that Minnesota's bullion transaction statute (Chapter 80G), which required dealers to register and post a surety bond for "Minnesota transactions" defined to include any transaction with a Minnesota resident regardless of location, violated the dormant Commerce Clause due to its extraterritorial effect. The court found the statute impermissibly regulated commerce occurring wholly outside Minnesota by forcing out-of-state dealers to seek Minnesota regulatory approval before conducting transactions with Minnesota residents in other states, and by attaching Minnesota law to in-state dealers wherever they transacted. The case was remanded for the district court to determine severability of the unconstitutional provisions.

Questions Presented

1. Whether Chapter 80G violates the dormant Commerce Clause by having an extraterritorial effect or excessively burdening interstate commerce.