[306 U.S. 72, 73] Messrs. Allan Watkins and Edgar Watkins, both of Atlanta, Ga., for appellant.
Messrs. O. H. Dukes, of Valdosta, Ga., and M. J. Yeomans, of Atlanta, Ga., for appellees.
Mr. Justice BUTLER delivered the opinion of the Court.
The question is whether, as applied in this case by the highest court of the State, the Georgia Maintenance Tax Act1 violates the commerce clause of article 1, 8, cl. 3, or the equal protection clause of the Fourteenth Amendment of the Constitution of the United States, U.S.C.A.
Appellant is an Ohio corporation engaged exclusively in interstate transportation as a common carrier of property for hire by motor vehicles, including hauling between points in Georgia and points in other States. A certificate of convenience and necessity issued by the Interstate Commerce Commission authorizing appellant's in [306 U.S. 72, 74] terstate transportation in Georgia,2 does not extend to transportation over rural post roads, which are roads not included in the state highway system over which United States mail is carried.