(1991) (“Considerations in favor of stare decisis are at their acme in cases involving property and contract rights, where reliance interests are involved[.]”); see also Planned Parenthood v. Casey, — U.S.-, -, 112 S.Ct. 2791, 2809, 120 L.Ed.2d 674 (1992) (“[T]he classic ease for weighing reliance heavily in favor of fobowing the earber rule occurs in the commercial contextf.]”). Upsetting what may very web be the legitimate expectations of one or more of the parties under the rubric of “treating similarly situated parties the same” may simply be unjustified. A similar concern for the rebanee interests of state and local governments imposing taxes motivated the plurahty’s opinion in American Trucking Ass’ns v. Smith, 496 U.S. 167, 182-83, 110 S.Ct. 2323, 2333, 110 L.Ed.2d 148 (1990) (<HOLDING>). In the tort context, however, a party’s
holding that previous decision invalidating highway use equalization tax should not be appbed retroactively because of inequity of unsettling actions taken in rebanee on overruled precedents holding that state legislature should determine whether to cure discriminatory tax by enforcing tax as to all or forgiving tax in its entirety holding that the essential purpose of use tax is the recoupment of lost sales tax revenue holding a tribe subject to 1 a tax on the use of certain highway motor vehicles 26 usc  4481a 2 a tax on diesel fuel used in highway vehicles 26 usc  4041a 3 a tax on special fuels used in motor vehicles 26 usc  4041b and 4 a tax on manufacturing in this case a truck chassis assembled by the tribe 26 usc  4061a 4218a holding contractor not responsible for use tax where tax exempt entity purchased the materials used