Collector v. Day
Collector v. Day is a significant Supreme Court case from 1871 that addressed the issue of tax immunities between federal and state governments. The case arose when the Court ruled that the federal government could not impose taxes on the income of state judges, aligning with the principle of dual sovereignty. This principle, articulated by Justice Samuel Nelson in the 8-1 majority opinion, emphasizes that both federal and state governments operate independently and retain their own sovereign powers unless explicitly delegated otherwise. The ruling drew upon the Tenth Amendment and contributed to the evolving legal landscape concerning the relationship between federal and state taxation powers. Although Collector v. Day represented a strong stance on dual sovereignty at the time, its authority diminished over the years, ultimately being weakened by subsequent cases like Helvering v. Gerhardt and overturned in Graves v. New York ex rel. O'Keefe. This case serves as a historical reference point in discussions of federalism and the limits of governmental authority in the context of taxation.
Collector v. Day
Date: April 3, 1871
Citation: 78 U.S. 113
Issue: Federalism
Significance: In a series of decisions on tax immunities, the Supreme Court held that the federal government could not tax the income of a state judge, based on dual sovereignty of the state and the federal government.
Collector is of historical interest for its place in a line of opinions on tax immunities that began with Chief Justice John Marshall’s opinion in McCulloch v. Maryland (1819). Marshall held that the state could not impose a tax on an institution created by the federal government. Following this line, the Court held in Dobbins v. Erie County (1842) that the state could not tax the income of a federal official.
In Collector, the opposite situation from Dobbins, the Court held that the federal government could not tax the income of a state judge. Justice Samuel Nelson wrote the 8-1 majority opinion; only Justice Joseph P. Bradley dissented. Nelson relied on the Tenth Amendment and on the theory of dual sovereignty to hold that both the state and federal governments were independent of each other and states retain all aspects of sovereignty not delegated to the national government. This was the strongest view of dual sovereignty presented by the Court, but it could not be sustained over time. Collector was substantially weakened by Helvering v. Gerhardt (1938) and directly overturned in Graves v. New York ex rel. O’Keefe (1939).