Of greater consequence, the Court further held that "issuing a policy of insurance is not a transaction of commerce," effectively removing the business of insurance beyond the United States Congress's legislative reach (until partially overturned in United States v. South-Eastern Underwriters Association).

Notwithstanding this refusal he undertook to act in the State as agent for the New York companies without any license.

He was then indicted and convicted in the Circuit Court of the city of Petersburg, and was sentenced to pay a fine of $50.

They may exclude the foreign corporation entirely; they may restrict its business to particular localities; or they may exact such security for the performance of its contracts with their citizens as in their judgment will best promote the public interests.

The whole matter rests in their discretion.In 1944, the Supreme Court overturned the holding of Paul v. Virginia in United States v. South-Eastern Underwriters Ass'n, finding that insurance transactions were subject to federal regulation under the Commerce Clause.