HYLTON v. UNITED STATES

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Case Basics
Petitioner 
Hylton
Respondent 
United States
Opinion 
Term:
Location: Congress
Facts of the Case 

In 1794, Congress enacted a law entitled "An act to lay duties upon carriages for the conveyance of persons." The law assessed a tax of sixteen dollars on each carriage owned by an individual or business. Hylton viewed the law as a direct tax in violation of the constitutional requirement that taxes passed by Congress must be apportioned, that is, laid according to the population and the number of representatives from each state.

Question 

Did Congress violate the Constitution and go beyond its taxing and spending powers in implementing the tax on carriages?

Conclusion 

The Court held that the tax was legitimate. In one of the seriatim opinions (each justice writing for himself, there being no opinion of the Court as a whole) which constituted the holding, Justice Chase argued that an apportioned tax on carriages would lead to inequalities in the tax burden between states. Furthermore, he interpreted the terms "tax" and "duty" in Article I, Section 8 broadly, and concluded that the carriage tax was an indirect tax. Justice Iredell argued that to administer an apportioned tax on carriages would be "absurd," for if a state had no carriages it would be impossible to implement the tax. He concluded that if a tax could not be apportioned, then it was not a direct tax "in the sense of the constitution."

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HYLTON v. UNITED STATES. The Oyez Project at IIT Chicago-Kent College of Law. 04 April 2014. <http://www.oyez.org/cases/1792-1850/1796/1796_2>.
HYLTON v. UNITED STATES, The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/1792-1850/1796/1796_2 (last visited April 4, 2014).
"HYLTON v. UNITED STATES," The Oyez Project at IIT Chicago-Kent College of Law, accessed April 4, 2014, http://www.oyez.org/cases/1792-1850/1796/1796_2.