Hylton v. United States
Case Date: 04/23/1796
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Hylton v. United States, 3 U.S. 171 (1796), was an early United States Supreme Court case in which the Court held that a tax on carriages did not violate the Article I, Section 9 requirement for the apportioning of direct taxes. It found the carriage tax was an "excise" instead of a "direct tax" requiring apportionment among the states by population. The Court noted that a tax on land was an example of a direct tax contemplated by the Constitution.
It is also significant for being the first case heard by the U.S. Supreme Court challenging the constitutionality of an act of Congress; In choosing to uphold the tax, the Court exercised judicial review, although they refrained from overturning the statute. While many say that Marbury v. Madison (1803) was the first case in which the Supreme Court exercised judicial review, this is not true. Marbury v. Madison was simply the first case in which the Supreme Court ruled an act of Congress unconstitutional [1]
The Justices at the time, rather than issuing a single opinion of the Court, instead issued seriatim opinions, with each writing separately and reading his own analysis in turn. The Court's interpretation of the federal tax power lasted until modified in Pollock v. Farmers' Loan & Trust Co. (1895), in which the Supreme Court held an unapportioned 1894 federal income tax on interest, dividends, and rents to be unconstitutional because the tax was a "direct tax" that had to be apportioned. The Pollock decision was superseded by the Sixteenth Amendment (1913), which allowed the Congress to impose a tax on incomes from "whatever source derived" without any requirement for apportionment.
Alexander Hamilton argued before court on behalf of the government, claiming that the tax was a valid use of the power of Congress. Justice James Iredell wrote, two days after the event: "Mr. Hamilton spoke in our Court, attended by the most crowded audience I ever saw there, both Houses of Congress being almost deserted on the occasion. Though he was in very ill health, he spoke with astonishing ability, and in a most pleasing manner, and was listened to with the profoundest attention. His speech lasted about three hours."
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