![]() |
Collector v. Day | |
---|---|
![]() | |
Argued February 3, 1871 Decided April 3, 1871 | |
Full case name | The Collector v. Day |
Citations | 78 U.S. 113 ( more ) |
Holding | |
Congress did not have the right within their powers to impose a tax on state officials. | |
Court membership | |
| |
Case opinions | |
Majority | Nelson, joined by Chase, Clifford, Swayne, Miller, Davis, Field, Strong |
Dissent | Bradley |
Superseded by | |
Graves v. New York (1939) |
Collector v. Day, 78 U.S. (11 Wall.) 113 (1871), was a United States Supreme Court case that questioned the United States Federal government's ability to impose a tax upon the "salary of a judicial officer of the State." Even though this particular case favors state employees' rights, it was overruled in 1939 by Graves v. New York, where the Supreme Court ruled that the income tax imposed by the State of New York on an employee of the Federal Home Owners Load Corporation was constitutional, since there was no requirement of immunity contained in the Constitution or in any act of Congress. Collector is still important to discussions of constitutional law because of Judge Nelson's statement of the doctrine of dual federalism in the case's opinion.
In 1864, various statutes passed by the United States Congress imposed a 5 percent tax on all personal incomes over $1000. [1] In 1866 and 1867, the tax collector for the internal revenue of the United States taxed Judge J.M. Day of the Court of Probate in Massachusetts. Since Judge Day believed this was not within the federal government's rights, he paid the amount of $61.50 under protest and then proceeded to sue the Circuit Court to recover his charges. After Day won this case, the United States issued a writ of error which brought the case to the Supreme Court of the United States.
The plaintiff's main argument, in this case the Collector, claimed that the Federal Government of the United States is supreme in the area of taxation given to them in the U.S. Constitution. Specifically, they cite this right in the Constitution, "Under the general rules of taxation, every man and everything throughout the country (exports excepted) are subject to taxation in the discretion of Congress..." They argued that since the Judge works for his own salary from the state, but as a citizen of the United States, Judge Day should pay his taxes to support the Federal government. They believed that just because he worked for the state, he should not be exempted from his duties as an American citizen.
Judge J.M. Day, the county probate judge of Massachusetts, argued that the Federal government is stretching their limits by taxing an officer of the State. He claimed that these powers are not expressly given to them in the Constitution, and that the Collector is ultimately violating State power.
Decided on April 3, 1871, in an 8 to 1 decision, the Supreme Court decided in favor of the Defendant, Judge Day. Justice Samuel Nelson delivered the opinion of the court and cites several court cases from the past, including McCulloch v. Maryland , Dobbins v. The Commission of Erie County, and Weston v. Charleston. Justice Nelson uses these examples to highlights the examples of federalism v. states powers. In his opinion, Nelson makes very clear that the national and state governments are part of one another but remain as "separate and distinct sovereignties, acting separately and independently of each other, within their respective spheres". [1] He makes his opinion stronger by stating that since it is already in the Constitution that that state may not tax the national government, then it should be the same way that the Federal government may not hinder upon state taxes. Justice Nelson refers to this action as the doctrine of "reciprocal immunity."
In the dissenting opinion delivered by Justice Bradley, he claims that he sees no distinct difference between the national government and the state government taxing the officials of the state. He claims that since every citizen living in a state is in fact a part of the United States, the national government has the ability to tax the officials of the states. Justice Bradley does not agree with the defendant's idea that being an official of a particular state makes him exempt from the federal law. He believes that if the court gives the states this right of taxing their own officials, then what would stop them from furthering their powers? He sees the gray line that this decision could bring about.
The Sixteenth Amendment to the United States Constitution allows Congress to levy an income tax without apportioning it among the states on the basis of population. It was passed by Congress in 1909 in response to the 1895 Supreme Court case of Pollock v. Farmers' Loan & Trust Co. The Sixteenth Amendment was ratified by the requisite number of states on February 3, 1913, and effectively overruled the Supreme Court's ruling in Pollock.
McCulloch v. Maryland, 17 U.S. 316 (1819), was a landmark U.S. Supreme Court decision that defined the scope of the U.S. Congress's legislative power and how it relates to the powers of American state legislatures. The dispute in McCulloch involved the legality of the national bank and a tax that the state of Maryland imposed on it. In its ruling, the Supreme Court established firstly that the "Necessary and Proper" Clause of the U.S. Constitution gives the U.S. federal government certain implied powers that are not explicitly enumerated in the Constitution, and secondly that the American federal government is supreme over the states, and so states' ability to interfere with the federal government is restricted.
Pollock v. Farmers' Loan & Trust Company, 157 U.S. 429 (1895), affirmed on rehearing, 158 U.S. 601 (1895), was a landmark case of the Supreme Court of the United States. In a 5-to-4 decision, the Supreme Court struck down the income tax imposed by the Wilson–Gorman Tariff Act for being an unapportioned direct tax. The decision was superseded in 1913 by the Sixteenth Amendment to the United States Constitution, which allows Congress to levy income taxes without apportioning them among the states.
United States v. Butler, 297 U.S. 1 (1936), is a U.S. Supreme Court case that held that the U.S. Congress has not only the power to lay taxes to the level necessary to carry out its other powers enumerated in Article I of the U.S. Constitution but also a broad authority to tax and spend for the "general welfare" of the United States. The decision itself concerned whether the processing taxes instituted by the 1933 Agricultural Adjustment Act were constitutional.
Printz v. United States, 521 U.S. 898 (1997), was a United States Supreme Court case in which the Court held that certain interim provisions of the Brady Handgun Violence Prevention Act violated the Tenth Amendment to the United States Constitution.
The enumerated powers of the United States Congress are the powers granted to the federal government of the United States. Most of these powers are listed in Article I, Section 8 of the United States Constitution.
The Taxing and Spending Clause, Article I, Section 8, Clause 1 of the United States Constitution, grants the federal government of the United States its power of taxation. While authorizing Congress to levy taxes, this clause permits the levying of taxes for two purposes only: to pay the debts of the United States, and to provide for the common defense and general welfare of the United States. Taken together, these purposes have traditionally been held to imply and to constitute the federal government's taxing and spending power.
Bailey v. Drexel Furniture Co., 259 U.S. 20 (1922), was a United States Supreme Court case in which the Court ruled the 1919 Child Labor Tax Law unconstitutional as an improper attempt by Congress to penalize employers using child labor. The Court indicated that the tax imposed by the statute was actually a penalty in disguise.
Steward Machine Company v. Davis, 301 U.S. 548 (1937), was a case in which the U.S. Supreme Court upheld the unemployment compensation provisions of the Social Security Act of 1935, which established the federal taxing structure that was designed to induce states to adopt laws for funding and payment of unemployment compensation. The decision signaled the Court's acceptance of a broad interpretation of Congressional power to influence state laws.
In the United States, judicial review is the legal power of a court to determine if a statute, treaty, or administrative regulation contradicts or violates the provisions of existing law, a State Constitution, or ultimately the United States Constitution. While the U.S. Constitution does not explicitly define the power of judicial review, the authority for judicial review in the United States has been inferred from the structure, provisions, and history of the Constitution.
Nullification, in United States constitutional history, is a legal theory that a state has the right to nullify, or invalidate, any federal laws which that state has deemed unconstitutional with respect to the United States Constitution. The theory of nullification has never been legally upheld by federal courts.
Springer v. United States, 102 U.S. 586 (1881), was a case in which the United States Supreme Court upheld the federal income tax imposed under the Revenue Act of 1864.
Smith v. Turner; Norris v. Boston, 48 U.S. 283 (1849), were two similar cases, argued together before the United States Supreme Court, which decided 5-4 that states do not have the right to impose a tax that is determined by the number of passengers of a designated category on board a ship and/or disembarking into the State. The cases are sometimes called the Passenger Case or Passenger Cases.
Canton Railroad Company v. Rogan, 340 U.S. 511 (1951), is a case in which the United States Supreme Court held that a state franchise tax upon the services performed by a railroad in handling imported and exported goods did not violate the Import-Export Clause of the United States Constitution.
The constitutional law of the United States is the body of law governing the interpretation and implementation of the United States Constitution. The subject concerns the scope of power of the United States federal government compared to the individual states and the fundamental rights of individuals. The ultimate authority upon the interpretation of the Constitution and the constitutionality of statutes, state and federal, lies with the Supreme Court of the United States.
National Federation of Independent Business v. Sebelius, 567 U.S. 519 (2012), was a landmark United States Supreme Court decision in which the Court upheld Congress's power to enact most provisions of the Patient Protection and Affordable Care Act (ACA), commonly called Obamacare, and the Health Care and Education Reconciliation Act (HCERA), including a requirement for most Americans to pay a penalty for forgoing health insurance by 2014. The Acts represented a major set of changes to the American health care system that had been the subject of highly contentious debate, largely divided on political party lines.
The Liberty Amendments: Restoring the American Republic is a book by the American talk radio host and lawyer Mark Levin, published in 2013. In it, Levin lays out and makes a case for eleven Constitutional amendments which he believes would restore the Constitution’s chief components: federalism, republicanism, and limited government.
Article I, § 10, clause 2 of the United States Constitution, known as the Import-Export Clause, prevents the states, without the consent of Congress, from imposing tariffs on imports and exports above what is necessary for their inspection laws and secures for the federal government the revenues from all tariffs on imports and exports. Several nineteenth century Supreme Court cases applied this clause to duties and imposts on interstate imports and exports. In 1869, the United States Supreme Court ruled that the Import-Export Clause only applied to imports and exports with foreign nations and did not apply to imports and exports with other states, although this interpretation has been questioned by modern legal scholars.
Brown v. Maryland, 25 U.S. 419 (1827), was a significant United States Supreme Court case which interpreted the Import-Export and Commerce Clauses of the U.S. Constitution to prohibit discriminatory taxation by states against imported items after importation, rather than only at the time of importation. The state of Maryland passed a law requiring importers of foreign goods to obtain a license for selling their products. Brown was charged under this law and appealed. It was the first case in which the U.S. Supreme Court construed the Import-Export Clause. Chief Justice John Marshall delivered the opinion of the court, ruling that Maryland's statute violated the Import-Export and Commerce Clauses and the federal law was supreme. He alleged that the power of a state to tax goods did not apply if they remained in their "original package". A license tax on the importer was essentially the same as a tax on an import itself. Despite arguing the case for Maryland, future chief justice Roger Taney admitted that the case was correctly decided.
Davis v. Michigan, 489 U.S. 803 (1989), is a case in the Supreme Court of the United States holding that states may not tax federal pensions if they exempt their own state pensions from taxation. In the 1930s, the federal and state governments began to charge income tax on salaries paid to each other's employees. However, reciprocal treatment was required under the doctrine of intergovernmental immunity. The Court's ruling extended the reciprocity to pensions, since they are a form of deferred compensation for services previously rendered by an employee.