Head Money Cases | |
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Argued November 19–20, 1884 Decided December 8, 1884 | |
Full case name | Edye and Another v. Robertson, Collector; Cunard Steamship Company v. Robertson; Same v. Same |
Citations | 112 U.S. 580 ( more ) 5 S. Ct. 247; 28 L. Ed. 798; 1884 U.S. LEXIS 1909; 3 A.F.T.R. (P-H) 2473 |
Case history | |
Prior | On writs of error from the Circuit Courts of the Eastern and Southern Districts of New York |
Holding | |
Treaties do not hold a privileged position above other acts of Congress, and other laws affecting their "enforcement, modification, or repeal" are legitimate. | |
Court membership | |
| |
Case opinion | |
Majority | Miller, joined unanimously |
Laws applied | |
U.S. Const. |
The Head Money Cases, 112 U.S. 580 (1884), also referred to as Edye v. Robertson, were a group of cases decided together by the United States Supreme Court. [1]
Pursuant to the Immigration Act of 1882, officers from the customhouse in the Port of New York began collecting a tax from ships of fifty cents for each immigrant aboard. Multiple ship owners sued because they were transporting Dutch immigrants, and the Netherlands had a treaty with the United States that seemed to prohibit the tax.
The case established the precedent that treaties, which are described in the Supremacy Clause of the US Constitution as "the supreme law of the land" equal to any domestic federal law, do not hold a privileged position above other acts of Congress. Hence, other laws affecting the "enforcement, modification, or repeal" of treaties are legitimate. [1] [2]
Article One of the Constitution of the United States establishes the legislative branch of the federal government, the United States Congress. Under Article One, Congress is a bicameral legislature consisting of the House of Representatives and the Senate. Article One grants Congress various enumerated powers and the ability to pass laws "necessary and proper" to carry out those powers. Article One also establishes the procedures for passing a bill and places various limits on the powers of Congress and the states from abusing their powers.
Article Six of the United States Constitution establishes the laws and treaties of the United States made in accordance with it as the supreme law of the land, forbids a religious test as a requirement for holding a governmental position, and holds the United States under the Constitution responsible for debts incurred by the United States under the Articles of Confederation.
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.
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 5–4 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.
The federal government of the United States is the common government of the United States, a federal republic located primarily in North America, comprising 50 states, five major self-governing territories, several island possessions, and the federal district of Washington, D.C., where the majority of the federal government is based.
United States v. Wong Kim Ark, 169 U.S. 649 (1898), was a landmark decision of the U.S. Supreme Court which held that "a child born in the United States, of parents of Chinese descent, who, at the time of his birth, are subjects of the Emperor of China, but have a permanent domicile and residence in the United States, and are there carrying on business, and are not employed in any diplomatic or official capacity under the Emperor of China", automatically became a U.S. citizen at birth. This decision established an important precedent in its interpretation of the Citizenship Clause of the Fourteenth Amendment to the Constitution.
Burrow-Giles Lithographic Co. v. Sarony, 111 U.S. 53 (1884), was a case decided by the Supreme Court of the United States that upheld the power of Congress to extend copyright protection to photography.
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.
The Citizenship Clause is the first sentence of the Fourteenth Amendment to the United States Constitution, which was adopted on July 9, 1868, which states:
All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the State wherein they reside.
Elk v. Wilkins, 112 U.S. 94 (1884), was a United States Supreme Court landmark 1884 decision with respect to the citizenship status of Indians.
The Treaty Clause of the United States Constitution establishes the procedure for ratifying international agreements. It empowers the President as the primary negotiator of agreements between the United States and other countries, and holds that the advice and consent of a two-thirds supermajority of the Senate renders a treaty binding with the force of federal law.
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.
Compagnie Francaise de Navigation a Vapeur v. Louisiana Board of Health, 186 U.S. 380 (1902), was a United States Supreme Court case which held constitutional state laws requiring the involuntary quarantine of individuals to prevent the spread of disease. Louisiana's quarantine laws, Justice Edward White said, were a reasonable exercise of the state's police power that conflicted with neither the Dormant Commerce Clause nor the Due Process Clause of the Fourteenth Amendment. In dissent, Justice Henry Billings Brown, joined by John Marshall Harlan, agreed that while quarantine laws were constitutional, Louisiana's went beyond the scope of the state's authority over interstate commerce, even violating several treaties between the United States and other nations.
The Supremacy Clause of the Constitution of the United States establishes that the Constitution, federal laws made pursuant to it, and treaties made under its authority, constitute the "supreme Law of the Land", and thus take priority over any conflicting state laws. It provides that state courts are bound by, and state constitutions subordinate to, the supreme law. However, federal statutes and treaties must be within the parameters of the Constitution; that is, they must be pursuant to the federal government's enumerated powers, and not violate other constitutional limits on federal power, such as the Bill of Rights—of particular interest is the Tenth Amendment to the United States Constitution, which states that the federal government has only those powers that are delegated to it by the Constitution. It is the responsibility of the United States Supreme Court in that case to exercise the power of judicial review: the ability to invalidate a statute for violating a provision of the Constitution.
Fong Yue Ting v. United States, 149 U.S. 698 (1893), decided by the United States Supreme Court on May 15, 1893, was a case challenging provisions in Section 6 of the Geary Act of 1892 that extended and amended the Chinese Exclusion Act of 1882. The provisions in question required Chinese in the United States to obtain certificates of residency and allowed for the arrest and the deportation of Chinese who had failed to obtain these certificates, even if they had not violated any other laws. The case involved writs of habeas corpus from Fong Yue Ting and two other Chinese citizens residing in New York City who were arrested and detained for not having certificates. The Supreme Court decision was in favor of the United States government, upholding the Geary Act and denying the writs of habeas corpus.
The Immigration Act of 1891, also known as the 1891 Immigration Act, was a modification of the Immigration Act of 1882, focusing on immigration rules and enforcement mechanisms for foreigners arriving from countries other than China. It was the second major federal legislation related to the mechanisms and authority of immigration enforcement, the first being the Immigration Act of 1882. The law was passed on March 3, 1891, at the end of the term of the 51st United States Congress, and signed into law by then United States President Benjamin Harrison.
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.