Hylton v. United States

Tue, 23 Feb 1796 13:00:00 +0000

Location

Congress

Constitution and Delaware Street Washington D.C. 20002

Washington 20002

United States

38° 53' 31.1496" N, 77° 0' 29.1744" W

See map: Google Maps

Case Basics

Petitioner

Hylton

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Interim Court (1796)

Opinion

3 U.S. 171 (1796)

Argued

Tuesday, February 23, 1796

Decided

Tuesday, March 8, 1796

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."

Ware v. Hylton

Sat, 06 Feb 1796 13:00:00 +0000

Case Basics

Petitioner

Ware

Petitioner Type

Petitioner

Respondent

Hylton

Respondent Type

Respondent

Heard By

Interim Court (1796)

Decided By

Interim Court (1796)

Opinion

3 U.S. 199 (1796)

Argued

Saturday, February 6, 1796

Decided

Monday, March 7, 1796

Facts of the Case

This case involved the Treaty of Paris, which established peace in 1783. A Virginian owed a debt to a British subject. A Virginia law provided for the confiscation of such debts on the ground the the debt was owed to an alien enemy. The British subject (actually, his administrator) sued in a federal court to recover on the bond. The administrator argued that the Treaty of Paris ensured the collection of such debts.

Question

Does the Treaty of Paris override an otherwise valid state law?

Conclusion

Four of the five justices wrote opinions. It was the practice of the day for the Court to issue opinions seriatim, or one after another. There was no "opinion for the Court." Collectively, the justices held that federal courts had the power to determine the constitutionality of state laws. They invalidated the Virginia law under the supremacy clause and, in the words of a distinguished scholar of the period, "established for all time [the Supreme Court's] power of judicial review of state laws."

Cases - 1796 term

Hylton v. United States

Location

Ware v. Hylton