Hylton V Us Case Study

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Hylton v. United States (1796)
Facts
A congressional act of 1794 imposed a $16 tax on each carriage owned by an individual. Daniel Hylton, who owned 125 carriages, claimed this act was a direct tax and should be apportioned according to the census. Hylton obtained review of an adverse judgment in the U.S. circuit court in Virginia.
Issue
Did Congress have the power under the Spending Clause to establish the tax on carriages?
Rule
The congressional act of 1974 imposed a tax on an individual’s carriage. Article I, section 2, clause 3 of the Constitution required Congress to apportion direct taxes according to the population among the states. Article I, section 9 declared direct taxes would be apportioned among the states based on the census …show more content…
According to Article I, section 9, direct taxes should be apportioned according to the census. He argued the tax was unconstitutional and void because it was allocated by uniformity instead of apportionment. The Constitution requires taxes to be allocated by uniformity for “duties, imposts, and excises,” none of which included taxes on carriages. Justice Clark stated Congress had the power to establish the tax on carriages under the Spending Clause, but it had to be allocated according to apportionment. According to the Court, direct taxes only included capitation and land taxes. Justice Paterson agreed with Justice Clark’s opinion on direct taxes. Justice Paterson believed capitation and land taxes were the only two direct taxes imposed by apportionment because the taxes protected the southern states. Justice Iredell argued the Constitution declared direct taxes had to be apportioned, and since this tax could not be imposed according to apportionment, it did not classify as a direct tax. It was impossible to fairly apportion the carriage tax because the ratio of carriages to population was not the same in each state. If a state did not have any carriages, the tax could not be apportioned at
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