Hawaii hotspot created at least 129 volcanoes, more than 123 of which are extinct volcanoes, seamounts, and atolls, four of which are active volcanoes, and two of which are dormant volcanoes. They can be organized into three general categories: the Hawaiian archipelago, which comprises most of the U.S. state of Hawaii and is the location of all modern volcanic activity; the Northwestern Hawaiian Islands, which consist of coral atolls, extinct islands, and atoll islands; and the Emperor Seamounts, all of which have since eroded and subsided to the sea and become seamounts and guyots (flat-topped seamounts). Hawaiian volcanoes are characterized by frequent
Dormant Commerce Clause Treasury of MD. v. Wynne", the Court addressed Maryland's unusual practice of taxing personal income earned in Maryland, and taxing personal income of its citizens earned outside Maryland, "without" any tax credit for income tax paid to other states. The Court held this sort of double-taxation to be a violation of the dormant Commerce Clause. The Court faulted Justice Antonin Scalia's criticism of the dormant Commerce Clause doctrine by saying that he failed to "explain why, under his interpretation of the Constitution, the Import-Export Clause would not lead to the same result that we reach under the dormant Commerce Clause".