Hylton v. United States
Encyclopedia
Hylton v. United States, , was an early United States Supreme Court
case in which the Court held that a tax on carriages did not violate the Article I, Section 9
requirement for the apportioning of direct taxes. It found the carriage tax was an "excise" instead of a "direct tax" requiring apportionment among the states by population. The Court noted that a tax on land
was an example of a direct tax contemplated by the Constitution.
It is also significant for being the first case heard by the U.S. Supreme Court challenging the constitutionality of an act of Congress; In choosing to uphold the tax, the Court exercised judicial review, although they refrained from overturning the statute. While many say that Marbury v. Madison
(1803) was the first case in which the Supreme Court exercised judicial review, this is not true. Marbury v. Madison was simply the first case in which the Supreme Court ruled an act of Congress unconstitutional
The Justices at the time, rather than issuing a single opinion of the Court, instead issued seriatim
opinions, with each writing separately and reading his own analysis in turn. The Court's interpretation of the federal tax power
lasted until modified in Pollock v. Farmers' Loan & Trust Co.
(1895), in which the Supreme Court held an unapportioned 1894 federal income tax on interest, dividends, and rents to be unconstitutional because the tax was a "direct tax" that had to be apportioned. The Pollock decision was superseded by the Sixteenth Amendment
(1913), which allowed the Congress to impose a tax on incomes from "whatever source derived" without any requirement for apportionment.
Alexander Hamilton
argued before court on behalf of the government, claiming that the tax was a valid use of the power of Congress. Justice James Iredell
wrote, two days after the event: "Mr. Hamilton spoke in our Court, attended by the most crowded audience I ever saw there, both Houses of Congress being almost deserted on the occasion. Though he was in very ill health, he spoke with astonishing ability, and in a most pleasing manner, and was listened to with the profoundest attention. His speech lasted about three hours."
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
case in which the Court held that a tax on carriages did not violate the Article I, Section 9
Article One of the United States Constitution
Article One of the United States Constitution describes the powers of Congress, the legislative branch of the federal government. The Article establishes the powers of and limitations on the Congress, consisting of a House of Representatives composed of Representatives, with each state gaining or...
requirement for the apportioning of direct taxes. It found the carriage tax was an "excise" instead of a "direct tax" requiring apportionment among the states by population. The Court noted that a tax on land
Land value tax
A land value tax is a levy on the unimproved value of land. It is an ad valorem tax on land that disregards the value of buildings, personal property and other improvements...
was an example of a direct tax contemplated by the Constitution.
It is also significant for being the first case heard by the U.S. Supreme Court challenging the constitutionality of an act of Congress; In choosing to uphold the tax, the Court exercised judicial review, although they refrained from overturning the statute. While many say that Marbury v. Madison
Marbury v. Madison
Marbury v. Madison, is a landmark case in United States law and in the history of law worldwide. It formed the basis for the exercise of judicial review in the United States under Article III of the Constitution. It was also the first time in Western history a court invalidated a law by declaring...
(1803) was the first case in which the Supreme Court exercised judicial review, this is not true. Marbury v. Madison was simply the first case in which the Supreme Court ruled an act of Congress unconstitutional
The Justices at the time, rather than issuing a single opinion of the Court, instead issued seriatim
Seriatim
Seriatim is a legal term typically used to indicate that a court is addressing multiple issues in a certain order, such as the order that the issues were originally presented to the court....
opinions, with each writing separately and reading his own analysis in turn. The Court's interpretation of the federal tax power
Taxing and Spending Clause
Article I, Section 8, Clause 1 of the United States Constitution, is known as the Taxing and Spending Clause. It is the clause that gives the federal government of the United States its power of taxation...
lasted until modified in Pollock v. Farmers' Loan & Trust Co.
Pollock v. Farmers' Loan & Trust Co.
Pollock v. Farmers' Loan & Trust Company, , aff'd on reh'g, , with a ruling of 5–4, was a landmark case in which the Supreme Court of the United States ruled that the unapportioned income taxes on interest, dividends and rents imposed by the Income Tax Act of 1894 were, in effect, direct taxes, and...
(1895), in which the Supreme Court held an unapportioned 1894 federal income tax on interest, dividends, and rents to be unconstitutional because the tax was a "direct tax" that had to be apportioned. The Pollock decision was superseded by the Sixteenth Amendment
Sixteenth Amendment to the United States Constitution
The Sixteenth Amendment to the United States Constitution allows the Congress to levy an income tax without apportioning it among the states or basing it on Census results...
(1913), which allowed the Congress to impose a tax on incomes from "whatever source derived" without any requirement for apportionment.
Alexander Hamilton
Alexander Hamilton
Alexander Hamilton was a Founding Father, soldier, economist, political philosopher, one of America's first constitutional lawyers and the first United States Secretary of the Treasury...
argued before court on behalf of the government, claiming that the tax was a valid use of the power of Congress. Justice James Iredell
James Iredell
James Iredell was one of the first Justices of the Supreme Court of the United States. He was appointed by President George Washington and served from 1790 until his death in 1799...
wrote, two days after the event: "Mr. Hamilton spoke in our Court, attended by the most crowded audience I ever saw there, both Houses of Congress being almost deserted on the occasion. Though he was in very ill health, he spoke with astonishing ability, and in a most pleasing manner, and was listened to with the profoundest attention. His speech lasted about three hours."