In Quill Corp. v. North Dakota, a state sales tax was imposed on out-of-state firms doing mail-order business with North Dakota residents. This law was found:

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The law was found unconstitutional in violation of the commerce clause because it discriminated against out-of-state businesses and placed an undue burden on interstate commerce. This ruling established the principle that states cannot impose sales taxes on out-of-state businesses unless they have a physical presence in the state.