Bailey v. Drexel Furniture Co.
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| Bailey v. Drexel Furniture Co. | |
| Reference: 259 U.S. 20 | |
| Term: 1922 | |
| Important Dates | |
| Argued: March 7-8, 1922 Decided: May 15, 1922 | |
| Outcome | |
| United States District Court for the Western District of North Carolina affirmed | |
| Majority | |
| William Howard Taft • Joseph McKenna • Oliver Wendell Holmes • William Rufus Day • Willis Van Devanter • Mahlon Pitney • James Clark McReynolds • Louis Brandeis | |
| Dissenting | |
| John Hessin Clarke | |
Bailey v. Drexel Furniture Co. was a case decided on May 15, 1922, by the United States Supreme Court holding that the Child Labor Tax Law violated the Tenth Amendment of the U.S. Constitution. The case concerned the constitutionality of the Child Labor Tax Law because it imposed regulations regarding the employment of children on the states. The Supreme Court affirmed the ruling of the United States District Court for the Western District of North Carolina.[1][2]
Why it matters: The Supreme Court's decision in this case established that Congress could not enact a law that attempted to impose regulations on the states. To read more about the impact of Bailey v. Drexel Furniture Co. click here.
Background
Congress enacted the Revenue Act of 1919, which was referred to as the Child Labor Tax Law. The law was responsible for enacting a tax of 10% of profits on companies that employed children under the age of 14. Drexel Furniture Company was responsible for paying $6,312.79 in taxes for violating the law in 1919. The company protested the tax, arguing that the law violated the Tenth Amendment of the U.S. Constitution.[1][2]
Oral argument
Oral argument was held between March 7, 1922, and March 8, 1922. The case was decided on May 15, 1922.[2]
Decision
The Supreme Court decided 8-1 to affirm the decision of the United States District Court for the Western District of North Carolina. Chief Justice William Howard Taft delivered the opinion of the court. Justice John Hessin Clarke dissented, however, he did not write an opinion.[2]
Opinions
Opinion of the court
Chief Justice William Howard Taft, writing for the court, argued that the tax imposed by the Child Labor Tax Law was not simply a tax, but was rather a penalty in an attempt to enforce a certain regulation on the states. Taft contended that Congress did not have jurisdiction to enforce such a penalty and therefore ruled that the law was invalid.[2]
| “ | The difference between a tax and a penalty is sometimes difficult to define, and yet the consequences of the distinction in the required method of their collection often are important. Where the sovereign enacting the law has power to impose both tax and penalty, the difference between revenue production and mere regulation may be immaterial, but not so when one sovereign can impose a tax only, and the power of regulation rests in another. Taxes are occasionally imposed in the discretion of the legislature on proper subjects with the primary motive of obtaining revenue from them and with the incidental motive of discouraging them by making their continuance onerous. They do not lose their character as taxes because of the incidental motive. But there comes a time in the extension of the penalizing features of the so-called tax when it loses its character as such and becomes a mere penalty with the characteristics of regulation and punishment. Such is the case in the law before us. Although Congress does not invalidate the contract of employment or expressly declare that the employment within the mentioned ages is illegal, it does exhibit its intent practically to achieve the latter result by adopting the criteria of wrongdoing and imposing its principal consequence on those who transgress its standard.[3] | ” |
| —William Howard Taft, majority opinion in Bailey v. Drexel Furniture Co.[2] | ||
Impact
| Federalism |
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| •Key terms • Court cases •Major arguments • State responses to federal mandates • Federalism by the numbers • Index of articles about federalism |
- See also: State sovereignty
Bailey v. Drexel Furniture Co. established that Congress cannot enact laws that attempt to impose regulations on the states. Congress did not have the authority to establish regulations for states regarding the employment of children because of state sovereignty. State sovereignty refers to the authority of states to govern and regulate their political affairs without interference.[2]
See also
External links
- Full text of case syllabus and opinions (Justia)
- Supreme Court of the United States
- Search Google News for this topic
Footnotes
- ↑ 1.0 1.1 Oyez, "Child Labor Tax Case," accessed September 26, 2022
- ↑ 2.0 2.1 2.2 2.3 2.4 2.5 2.6 Justia, "Bailey v. Drexel Furniture Co., 259 U.S. 20 (1922)," accessed September 26, 2022
- ↑ Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
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