Hylton v. United States
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| Hylton v. United States | |
| Reference: 3 U.S. 171 | |
| Term: 1796 | |
| Important Dates | |
| Argued: February 23-25, 1796 Decided: March 8, 1796 | |
| Outcome | |
| Circuit Court for the District of Virginia affirmed | |
| Majority | |
| Samuel Chase • William Paterson • James Iredell • James Wilson • William Cushing | |
Hylton v. United States is a case decided on March 8, 1796, by the United States Supreme Court that concerned whether a tax on the possession of goods must be apportioned among the states according to their populations. The Supreme Court affirmed the ruling of the Circuit Court for the District of Virginia, holding that Congress did not violate the Constitution because direct taxes do not include taxes on the possession of goods. The case established the precedent for judicial review, which grants the Court the power to overturn legislative or executive actions that are inconsistent with the law.[1][2]
Why it matters: The Supreme Court's decision in this case established the precedent for judicial review, which is the power of the Court to interpret the law and overturn legislative or executive actions that are inconsistent with the law. The power of judicial review was formalized by Marbury v. Madison in 1803. To read more about the impact of Hylton v. United States click here.
Background
Congress enacted a law on June 6, 1794, to tax sixteen dollars on all carriages. Daniel Hylton argued that the carriage tax was a direct tax and therefore violated the constitutional requirement for direct taxes to be apportioned by the population of each state.[1]
Hylton pursued the case in the Circuit Court for the District of Virginia. The Circuit Court was divided over the definition of direct taxation, which led the case to be moved to the Supreme Court as a writ of error directed at the Circuit Court. The Supreme Court heard arguments regarding the definition of direct and indirect taxation to determine the constitutionality of the tax. The Supreme Court decided on March 8, 1796 to affirm the decision of the Circuit Court that the tax was constitutional.[2][3]
Oral argument
Oral argument was held between February 23, 1796, and February 25, 1796. The case was decided on March 8, 1796.[1]
Decision
The Supreme Court decided unanimously to affirm the Circuit Court's decision that the carriage tax was not a direct tax and was therefore constitutional. The justices delivered their opinions seriatim, meaning that each justice wrote and delivered individual opinions on the case. Opinions were heard by Samuel Chase, William Paterson, James Iredell, James Wilson, and William Cushing. Chief Justice Oliver Ellsworth was sworn into office on March 4, 1796, and did not participate in the decision.[4]
Opinions
Opinion of the court
The Court delivered their opinions seriatim, meaning that each justice delivered an opinion on the case as opposed to having a single opinion delivered on behalf of the court.
Justice Samuel Chase argued that the carriage tax was an indirect tax because it is a consumable commodity. The tax was therefore constitutional and was not subject to apportionment by state population.
| “ | I think, an annual tax on carriages for the conveyance of persons, may be considered as within the power granted to Congress to lay duties. The term duty, is the most comprehensive next to the generical term tax; and practically in Great Britain, (whence we take our general ideas of taxes, duties, imposts, excises, customs, etc.) embraces taxes on stamps, tolls for passage, etc. etc. and is not confined to taxes on importation only. It seems to me, that a tax on expence is an indirect tax; and I think, an annual tax on a carriage for the conveyance of persons, is of that kind; because a carriage is a consumeable commodity; and such annual tax on it, is on the expence of the owner. I am inclined to think, but of this I do not give a judicial opinion, that the direct taxes contemplated by the Constitution, are only two, to wit, a capitation, or poll tax, simply, without regard to property, profession, or any other circumstance; and a tax on LAND. I doubt whether a tax, by a general assessment of personal property, within the United States, is included within the term direct tax. As I do not think the tax on carriages is a direct tax, it is unnecessary, at this time, for me to determine, whether this court, constitutionally possesses the power to declare an act of Congress void, on the ground of its being made contrary to, and in violation of, the Constitution; but if the court have such power, I am free to declare, that I will never exercise it, but in a very clear case. I am for affirming the judgment of the Circuit Court.[5] | ” |
| —Samuel Chase, opinion in Hylton v. United States[4] | ||
Justice William Paterson also argued that the carriage tax was constitutional because it was an indirect tax and therefore was not subject to apportionment by state population.
| “ | The truth is that the articles taxed in one state should be taxed in another; in this way the spirit of jealousy is appeased and tranquility preserved; in this way the pressure on industry will be equal in the several states, and the relation between the different subjects of taxation duly preserved. Apportionment is an operation on states, and involves valuations and assessments which are arbitrary and should not be resorted to but in case of necessity. Uniformity is an instant operation on individuals, without the intervention of assessments or any regard to states, and is at once easy, certain, and efficacious. All taxes on expenses or consumption are indirect taxes. A tax on carriages is of this kind, and of course is not a direct tax. Indirect taxes are circuitous modes of reaching the revenue of individuals, who generally live according to their income.[5] | ” |
| —William Paterson, opinion in Hylton v. United States[2] | ||
Justice James Iredell argued that the carriage tax was not a direct tax because it cannot be apportioned and instead must be applied uniformly among the states.
| “ | It is sufficient on the present occasion for the Court to be satisfied that this is not a direct tax contemplated by the Constitution in order to affirm the present judgment, since if it cannot be apportioned, it must necessarily be uniform. I am clearly of opinion this is not a direct tax in the sense of the Constitution, and therefore that the judgment ought to be affirmed.[5] | ” |
| —James Iredell, opinion in Hylton v. United States[2] | ||
Justice James Wilson concluded in agreement with the other justices that the carriage tax was constitutional.
| “ | As there were only four judges, including myself, who attended the argument of this cause, I should have thought it proper to join in the decision, though I had before expressed a judicial opinion on the subject in the Circuit Court of Virginia, did not the unanimity of the other three judges relieve me from the necessity. I shall now, however, only add that my sentiments in favor of the constitutionality of the tax in question have not been changed.[5] | ” |
| —James Wilson, opinion in Hylton v. United States[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
Hylton v. United States contributed to the development of judicial review, which refers to the power of the court to overturn legislative or executive actions that are inconsistent with the law. The case demonstrated the Supreme Court's authority to determine the constitutionality of the carriage tax.[3]
The origin of judicial review is often credited to Marbury v. Madison in 1803, however, the precedent for judicial review was first established in Hylton v. United States by allowing the Supreme Court to determine the constitutionality of a tax enacted by Congress. The Court's decision ultimately upheld the actions of Congress, however, the case demonstrated the power of the courts to interpret the law and overturn legislative or executive actions that are determined to be unconstitutional. This power was later solidified by Marbury v. Madison in which judicial review was formally established.[3]
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 Oyez, "Hylton v. United States," accessed May 25, 2022
- ↑ 2.0 2.1 2.2 2.3 2.4 Justia, "Hylton v. United States," accessed May 25, 2022
- ↑ 3.0 3.1 3.2 Journal of the American Revolution, "Hylton v. U.S. and Alexander Hamilton's Defense of Congressional Taxing Authority," June 25, 2020
- ↑ 4.0 4.1 FindLaw, "Hylton v. United States," accessed May 26, 2022
- ↑ 5.0 5.1 5.2 5.3 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
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