Quill modified an earlier court decision, National Bellas Hess, Inc. v. Department of Revenue of Illinois, which dealt with a state imposing the duty of use tax collection on a mail order reseller. The decision in Quill has been a point of contention for states as e-Commerce had grown greatly during the 21st century.
The Quill case challenged an earlier court verdict, National Bellas Hess, Inc. v. Department of Revenue of Illinois, which addressed a state's obligation to collect use tax from an online retailer. The Quill decision has been a source of disagreement among states as e-commerce expanded significantly in the 21st century.