Commonwealth of Massachusetts v. Mellon
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| Commonwealth of Massachusetts v. Mellon | |
| Reference: 262 U.S. 447 | |
| Term: 1923 | |
| Important Dates | |
| Argued: May 3-4, 1923 Decided: June 4, 1923 | |
| Outcome | |
| United States Court of Appeals for the District of Columbia Circuit affirmed | |
| Majority | |
| George Sutherland • William Howard Taft • Joseph McKenna • Oliver Wendell Holmes • Willis Van Devanter • James Clark McReynolds • Louis Brandeis • Pierce Butler • Edward Terry Sanford | |
Commonwealth of Massachusetts v. Mellon is a case decided on June 4, 1923, by the United States Supreme Court holding that federal statutes administered to impose additional taxation upon a large number of taxpayers were not a matter of individual concern. The case concerned whether the Maternity Act of 1921 violated the Fifth Amendment of the U.S. Constitution. The Supreme Court affirmed the decision of the United States Court of Appeals for the District of Columbia Circuit.[1][2][3]
Why it matters: The Supreme Court's decision in this case established that Congress could enact federal legislation that imposed additional taxation on the general public. To read more about the impact of Commonwealth of Massachusetts v. Mellon click here.
Background
The Maternity Act of 1921 was enacted by Congress to provide funding to states that cooperated with provisions to reduce maternal and infant mortality. An individual from Massachusetts filed a suit, arguing that the act was unconstitutional. The individual claimed that the act would create tax burdens that violated citizens' due process right.[1][3]
Oral argument
Oral argument was held between May 3, 1923, and May 4, 1923. The case was decided on June 4, 1923.[1]
Decision
The Supreme Court decided unanimously to affirm the decision of the United States Court of Appeals for the District of Columbia Circuit. Justice George Sutherland delivered the opinion of the court.[2]
Opinions
Opinion of the court
Justice George Sutherland, writing for the court, argued that the administration of legislation that would increase taxation is a public concern, not an individual concern. Sutherland contended that the Maternity Act was therefore constitutional and that the suit that had been filed could not be maintained.[2]
| “ | The administration of any statute likely to produce additional taxation to be imposed upon a vast number of taxpayers, the extent of whose several liability is indefinite and constantly changing, is essentially a matter of public, and not of individual, concern. If one taxpayer may champion and litigate such a cause, then every other taxpayer may do the same, not only in respect of the statute here under review, but also in respect of every other appropriation act and statute whose administration requires the outlay of public money and whose validity may be questioned. The bare suggestion of such a result, with its attendant inconveniences, goes far to sustain the conclusion which we have reached, that a suit of this character cannot be maintained. It is of much significance that no precedent sustaining the right to maintain suits like this has been called to our attention, although, since the formation of the government, as an examination of the acts of Congress will disclose, a large number of statutes appropriating or involving the expenditure of moneys for nonfederal purposes have been enacted and carried into effect.[4] | ” |
| —George Sutherland, majority opinion in Commonwealth of Massachusetts v. Mellon[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: Judicial review
Commonwealth of Massachusetts v. Mellon established that Congress had the authority to enact federal legislation that would impose additional taxation on the general public. The decision in this case affirmed that the Supreme Court did not have the authority to review or annul congressional acts unless an individual was proved to have suffered or be in danger of suffering an injury as a direct result of the legislation. This case did not fall within the scope of judicial review because the act affected the general public and was not a matter of individual concern.[1][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 1.2 1.3 Oyez, "Commonwealth of Massachusetts v. Mellon," accessed July 28, 2022
- ↑ 2.0 2.1 2.2 2.3 2.4 Justia, "Commonwealth of Massachusetts v. Mellon, 262 U.S. 447 (1923)," accessed July 28, 2022
- ↑ 3.0 3.1 LexisNexis, "Massachusetts v. Mellon - 262 U.S. 447, 43 S. Ct. 597 (1923)," accessed July 28, 2022
- ↑ Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
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