Arkadelphia Milling Co. v. St. Louis S.W. Ry
In Arkadelphia Milling Co. v. St. Louis S.W. Ry., 249 U.S. 134, 39 S.Ct. 237, 63 L.Ed. 517 (1919), the Supreme Court held that the movement of rough lumber from the forest to a mill, where it was made into barrel hoops and staves, was not interstate commerce even though ninety-five percent of the hoops and staves went on to other states. Id. at 151, 39 S.Ct. at 244.
The Court stated:
It is not merely that there was no continuous movement from the forest to the points without the State, but that when the rough material left the woods it was not intended that it should be transported out of the State, or elsewhere beyond the mill, until it had been subjected to a manufacturing process that materially changed its character, utility, and value. Id.