{
  "id": 214,
  "slug": "1934-us-louisiana-newspaper-tax-grosjean",
  "title": "United States: Louisiana taxes large newspapers' advertising revenue; the tax is struck down in Grosjean v. American Press Co.",
  "occurred_on": "1934-07-12",
  "occurred_on_precision": "day",
  "ended_on": null,
  "jurisdiction": "US-LA",
  "country": "US",
  "continent": "north-america",
  "level": "state_or_province",
  "type": null,
  "tactic_primary": "funding_and_ownership_pressure",
  "leader_slug": "oscar-k-allen",
  "issue_of_the_day": "The tax followed Senator Huey Long's rise to dominate Louisiana politics after his election to the United States Senate in 1932, and applied to the state's largest newspapers.",
  "outcome": "reversed",
  "outcome_on": "1936-02-10",
  "outcome_note": "The Supreme Court's ruling voided the tax and left Louisiana's large newspapers free of it.",
  "granularity": "anchor",
  "era": "1930s",
  "summary": "Louisiana taxed the gross receipts that businesses earned from advertising in newspapers with circulations above 20,000 copies a week, a threshold that caught the state's largest papers. The Supreme Court of the United States ruled unanimously in 1936 that the tax operated as a restraint on advertising revenue and circulation, and struck it down.{c:893}{c:894}{c:895}{c:898}",
  "what_happened": "The Louisiana Legislature passed Act No. 23 on July 12, 1934, taxing 2 percent of the gross receipts that businesses earned from placing advertisements in any newspaper, magazine or periodical with a circulation of more than 20,000 copies a week. The tax was adopted under the influence of United States Senator Huey Long, who had maintained control over the state legislature after his election to the Senate in 1932. Nine publishers whose papers met the circulation threshold sued to stop the tax, and their case reached the Supreme Court of the United States as Grosjean v. American Press Co. On February 10, 1936, the Court ruled unanimously, in an opinion by Justice George Sutherland, that the tax violated the free press and due process protections that the Fourteenth Amendment to the United States Constitution carries into state law. Sutherland wrote that the tax operated as a restraint in two ways, cutting the revenue newspapers earned from advertising and tending to restrict their circulation, and that its form, based on circulation rather than the volume of advertisements, was itself suspicious. The Court did not question Louisiana's general power to tax newspapers like other businesses; it found only that this particular tax was not an ordinary one.{c:893}{c:894}{c:895}{c:896}{c:897}{c:898}",
  "stated_justification": "Louisiana did not argue in court that newspaper owners were exempt from ordinary business taxes; the tax was defended as a routine exercise of the state's general taxing power rather than a measure aimed at the press.{c:896}",
  "effect_on_reporting": "The tax cut into the revenue newspapers earned from advertising and tended to restrict their circulation, according to the Supreme Court's opinion.{c:893}{c:894}{c:895}{c:896}{c:897}{c:898}",
  "unknowns": null,
  "status": "historical",
  "status_updated_on": "2026-09-26",
  "external_ids": {},
  "illustration_key": null,
  "pub_state": "published",
  "published_at": "2026-09-26T18:07:08Z",
  "reviewed_on": "2026-09-26",
  "next_review_on": "2027-03-26",
  "revision": 5,
  "created_at": "2026-09-26T18:07:02Z",
  "updated_at": "2026-09-26T18:14:34Z",
  "stage": "pressure",
  "ladder_note": null,
  "country_name": "United States",
  "tactics": [
    "funding_and_ownership_pressure"
  ],
  "leader": {
    "slug": "oscar-k-allen",
    "name": "Oscar K. Allen",
    "url": "https://thewaronnews.com/leaders/oscar-k-allen"
  },
  "url": "https://thewaronnews.com/incidents/1934-us-louisiana-newspaper-tax-grosjean",
  "page_meta": {
    "published": "2026-09-26T18:07:08Z",
    "reviewed": "2026-09-26",
    "sources": 2,
    "status": "historical",
    "statusAsOf": "2026-09-26",
    "unknowns": null
  },
  "actors": [
    {
      "slug": "george-sutherland",
      "name": "George Sutherland",
      "kind": "person",
      "role": "ruled",
      "role_at_time": null,
      "url": "https://thewaronnews.com/actors/george-sutherland"
    },
    {
      "slug": "huey-long",
      "name": "Huey P. Long",
      "kind": "person",
      "role": "other",
      "role_at_time": null,
      "url": "https://thewaronnews.com/actors/huey-long"
    }
  ],
  "outlets": [],
  "journalists": [],
  "cases": [],
  "related": [],
  "events": [],
  "claims": [
    {
      "id": 893,
      "subject_type": "incident",
      "subject_id": 214,
      "field": "occurred_on",
      "value": "Act No. 23 enacted July 12, 1934",
      "statement": "The Louisiana Legislature enacted the tax through Act No. 23 on July 12, 1934.",
      "attribution": null,
      "source_id": 576,
      "evidence_quote": "the act of the Legislature of Louisiana known as Act No. 23, passed and approved July 12, 1934",
      "evidence_date": "1936-02-10",
      "method": "court_record",
      "verified_at": "2026-09-26",
      "confidence": "high",
      "status": "current",
      "supersedes_id": null,
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      "supersede_reason": null,
      "batch_label": "historical-2026-09-26",
      "created_at": "2026-09-26T18:07:02Z",
      "source": {
        "id": 576,
        "url": "https://www.law.cornell.edu/supremecourt/text/297/233",
        "final_url": "https://www.law.cornell.edu/supremecourt/text/297/233",
        "title": "Grosjean v. American Press Co., Inc., 297 U.S. 233 (1936)",
        "publisher": "Grosjean v. American Press Co., Inc., 297 U.S. 233 (1936)",
        "published_on": "1936-02-10",
        "link_state": "live",
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        "wayback_url": null,
        "wayback_saved_at": null
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      "url": "https://thewaronnews.com/claims/893"
    },
    {
      "id": 894,
      "subject_type": "incident",
      "subject_id": 214,
      "field": "action",
      "value": "Tax operated as a restraint on advertising and circulation",
      "statement": "Justice George Sutherland's opinion held that the tax operated as a restraint in two ways, cutting revenue from advertising and tending to restrict circulation.",
      "attribution": null,
      "source_id": 576,
      "evidence_quote": "It thus operates as a restraint in a double sense. First, its effect is to curtail the amount of revenue realized from advertising; and, second, its direct tendency is to restrict circulation.",
      "evidence_date": "1936-02-10",
      "method": "court_record",
      "verified_at": "2026-09-26",
      "confidence": "high",
      "status": "current",
      "supersedes_id": null,
      "superseded_by": null,
      "supersede_reason": null,
      "batch_label": "historical-2026-09-26",
      "created_at": "2026-09-26T18:07:03Z",
      "source": {
        "id": 576,
        "url": "https://www.law.cornell.edu/supremecourt/text/297/233",
        "final_url": "https://www.law.cornell.edu/supremecourt/text/297/233",
        "title": "Grosjean v. American Press Co., Inc., 297 U.S. 233 (1936)",
        "publisher": "Grosjean v. American Press Co., Inc., 297 U.S. 233 (1936)",
        "published_on": "1936-02-10",
        "link_state": "live",
        "link_state_since": "2026-09-26T18:11:00Z",
        "wayback_url": null,
        "wayback_saved_at": null
      },
      "url": "https://thewaronnews.com/claims/894"
    },
    {
      "id": 895,
      "subject_type": "incident",
      "subject_id": 214,
      "field": "action",
      "value": "Tax's form measured by circulation was suspicious",
      "statement": "Sutherland found the tax's form itself suspicious because it was measured by the extent of a newspaper's circulation rather than by the volume of its advertising.",
      "attribution": null,
      "source_id": 576,
      "evidence_quote": "The form in which the tax is imposed is in itself suspicious. It is not measured or limited by the volume of advertisements.",
      "evidence_date": "1936-02-10",
      "method": "court_record",
      "verified_at": "2026-09-26",
      "confidence": "high",
      "status": "current",
      "supersedes_id": null,
      "superseded_by": null,
      "supersede_reason": null,
      "batch_label": "historical-2026-09-26",
      "created_at": "2026-09-26T18:07:04Z",
      "source": {
        "id": 576,
        "url": "https://www.law.cornell.edu/supremecourt/text/297/233",
        "final_url": "https://www.law.cornell.edu/supremecourt/text/297/233",
        "title": "Grosjean v. American Press Co., Inc., 297 U.S. 233 (1936)",
        "publisher": "Grosjean v. American Press Co., Inc., 297 U.S. 233 (1936)",
        "published_on": "1936-02-10",
        "link_state": "live",
        "link_state_since": "2026-09-26T18:11:00Z",
        "wayback_url": null,
        "wayback_saved_at": null
      },
      "url": "https://thewaronnews.com/claims/895"
    },
    {
      "id": 896,
      "subject_type": "incident",
      "subject_id": 214,
      "field": "stated_justification",
      "value": "Court found no dispute that newspapers could face ordinary taxation",
      "statement": "The Supreme Court noted that no one suggested newspaper owners were immune from ordinary forms of taxation, distinguishing this tax from a routine business tax.",
      "attribution": null,
      "source_id": 576,
      "evidence_quote": "the owners of newspapers are immune from any of the ordinary forms of taxation for support of the government",
      "evidence_date": "1936-02-10",
      "method": "court_record",
      "verified_at": "2026-09-26",
      "confidence": "high",
      "status": "current",
      "supersedes_id": null,
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      "supersede_reason": null,
      "batch_label": "historical-2026-09-26",
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      "source": {
        "id": 576,
        "url": "https://www.law.cornell.edu/supremecourt/text/297/233",
        "final_url": "https://www.law.cornell.edu/supremecourt/text/297/233",
        "title": "Grosjean v. American Press Co., Inc., 297 U.S. 233 (1936)",
        "publisher": "Grosjean v. American Press Co., Inc., 297 U.S. 233 (1936)",
        "published_on": "1936-02-10",
        "link_state": "live",
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        "wayback_url": null,
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      },
      "url": "https://thewaronnews.com/claims/896"
    },
    {
      "id": 897,
      "subject_type": "incident",
      "subject_id": 214,
      "field": "reversed_on",
      "value": "Unanimous Court struck down the tax as a license tax",
      "statement": "Writing for a unanimous Supreme Court, Justice George Sutherland classified the Louisiana tax as a license tax and struck it down.",
      "attribution": null,
      "source_id": 577,
      "evidence_quote": "Writing for a unanimous Court, Justice George Sutherland classified the tax as a “license tax.”",
      "evidence_date": null,
      "method": "outlet_report",
      "verified_at": "2026-09-26",
      "confidence": "medium",
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      "batch_label": "historical-2026-09-26",
      "created_at": "2026-09-26T18:07:05Z",
      "source": {
        "id": 577,
        "url": "https://firstamendment.mtsu.edu/article/grosjean-v-american-press-co/",
        "final_url": "https://firstamendment.mtsu.edu/article/grosjean-v-american-press-co/",
        "title": "Grosjean v. American Press Co. (1936)",
        "publisher": "Grosjean v. American Press Co. (1936)",
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      "url": "https://thewaronnews.com/claims/897"
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    {
      "id": 898,
      "subject_type": "incident",
      "subject_id": 214,
      "field": "action",
      "value": "Tax adopted under Huey Long's influence",
      "statement": "The tax was adopted in 1934 under the influence of United States Senator Huey Long, who had controlled the Louisiana legislature since his election to the Senate in 1932.",
      "attribution": null,
      "source_id": 577,
      "evidence_quote": "under the influence of Sen. Huey Long, a former governor who maintained control over the legislature after being elected as a U.S. senator in 1932",
      "evidence_date": null,
      "method": "outlet_report",
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      "confidence": "medium",
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      "source": {
        "id": 577,
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        "final_url": "https://firstamendment.mtsu.edu/article/grosjean-v-american-press-co/",
        "title": "Grosjean v. American Press Co. (1936)",
        "publisher": "Grosjean v. American Press Co. (1936)",
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        "link_state": "live",
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        "wayback_url": null,
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      "url": "https://thewaronnews.com/claims/898"
    }
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  "sources": [
    {
      "id": 576,
      "url": "https://www.law.cornell.edu/supremecourt/text/297/233",
      "final_url": "https://www.law.cornell.edu/supremecourt/text/297/233",
      "title": "Grosjean v. American Press Co., Inc., 297 U.S. 233 (1936)",
      "publisher": "Grosjean v. American Press Co., Inc., 297 U.S. 233 (1936)",
      "published_on": "1936-02-10",
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      "final_url": "https://firstamendment.mtsu.edu/article/grosjean-v-american-press-co/",
      "title": "Grosjean v. American Press Co. (1936)",
      "publisher": "Grosjean v. American Press Co. (1936)",
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  "revisions_url": "https://thewaronnews.com/incidents/1934-us-louisiana-newspaper-tax-grosjean/revisions",
  "license": {
    "name": "CC BY 4.0",
    "url": "https://creativecommons.org/licenses/by/4.0/"
  },
  "cite_as": "United States: Louisiana taxes large newspapers' advertising revenue; the tax is struck down in Grosjean v. American Press Co.. The War On News, thewaronnews.com. https://thewaronnews.com/incidents/1934-us-louisiana-newspaper-tax-grosjean. Retrieved 2026-09-26."
}