Hylton v. United States
| Hylton v. United States | |
|---|---|
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| Argued February 23, 1796 Decided March 8, 1796 |
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| Full case name | Daniel Hylton, Plaintiff in Error v. The United States |
| Citations | 3 U.S. 171 (more)
3 U.S. (3 Dall.) 171; 1 L. Ed. 556; 1796 U.S. LEXIS 397; 2 A.F.T.R. (P-H) 2155
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| Prior history | Defendant convicted, Circuit Court for the District of Virginia |
| Subsequent history | None |
| Holding | |
| A tax on the possession of goods is not a "direct" tax, which must be apportioned under Article I of the Constitution. | |
| Court membership | |
| Seriatim opinion | Chase |
| Seriatim opinion | Paterson |
| Seriatim opinion | Iredell |
| Seriatim opinion | Wilson |
| Ellsworth and Cushing took no part in the consideration or decision of the case. | |
| Laws applied | |
| U.S. Const. art. I | |
Hylton v. United States, 3 U.S. 171 (1796), is an early United States Supreme Court case in which the Court held that a yearly tax on carriages did not violate the Article I, Section 2, Clause 3 and Article I, Section 9, Clause 3 requirements for the apportioning of direct taxes. The Court concluded that the carriage tax was not 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.
The case is also significant for being the first one 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 it 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
Alexander Hamilton argued before the 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."
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. Justice Chase wrote, “As I do not think the tax on carriages is a direct tax…I am for affirming the judgment of the Circuit Court.” Justice Paterson wrote, “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...I am, therefore, of opinion, that the judgment rendered in the Circuit Court of Virginia ought to be affirmed.” Justice Iredell wrote, “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.” And Justice Wilson wrote, "I shall now, however, only add, that my sentiments, in favor of the constitutionality of the tax in question, have not been changed.”
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