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Since its initial attempts in the mid-to-late 1800s to interpret the privileges and immunities clause of article IV-"The Citizens of each State shall be entitled to all Privileges and Immunities of Citizens in the several States" '-the Supreme Court has modified materially its express method of analyzing claims arising under the clause. Its operative method, however, has remained relatively unchanged. Through the early part of the twentieth century, the Court expressly treated as critical a question framed and assigned overriding importance in Corfield v. Coryell,2 a leading circuit court decision of 1823: is the privilege or immunity at issue one of "those privileges and immunities which are, in their nature, fundamental; which belong, of right, to the citizens of all free governments"? 3 Thus, according to the Court, laws were unconstitutional that dis-

Discrimination against Nonresidents and the Privileges and Immunities Clause of Article IV