Law School Case Brief
Hylton v. United States - 3 U.S. (3 Dall.) 171 (1796)
A general power is given to Congress, to lay and collect taxes, of every kind or nature, without any restraint, except only on exports; but two rules are prescribed for their government, namely, uniformity and apportionment: Three kinds of taxes, to wit, duties, imposts, and excises by the first rule, and capitation, or other direct taxes, by the second rule.
An action of debt was instituted in the name of the United States, against Daniel Hylton, to recover a penalty imposed by the act of Congress for not entering, and paying the duty on, a number of carriages, for the conveyance of persons, which he kept for his own use. The defendant pleaded nil debet, whereupon issue was joined. The circuit court noted that the debtor was aware of the act's requirements but that he refused to pay the required duties, alleging that the law was unconstitutional and void. The circuit court found the debtor liable to pay the tax, and the debtor confessed judgment as the foundation for the writ of error to the Court to try the law's constitutionality.
Was the law constitutional?
The Court affirmed the circuit court's judgment, finding that such a tax was within Congress's power to lay duties and that because a carriage was a consumable commodity, an annual tax on it was on the debtor's expense as owner of the carriages.
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