Dobbins v. Erie County
Dobbins v. Erie County is a significant case in U.S. legal history that addresses the intersection of state and federal taxation powers. In this case, a ship captain challenged a Pennsylvania tax on his federal income, leading to a legal battle over the legality of state taxation on federal earnings. The Pennsylvania Supreme Court initially upheld the tax, but the U.S. Supreme Court unanimously reversed this decision. The Court's ruling emphasized that such taxation would infringe upon the powers of the national government, reinforcing the principle of federalism. This case held historical importance during the nineteenth century, echoing the earlier Supreme Court decision in McCulloch v. Maryland, which established that both federal and state governments should not impose taxes upon one another. Dobbins v. Erie County's interpretation of federalism and taxation remained influential until it was indirectly overturned in 1939. This case remains a relevant reference point in discussions about the limits of state authority concerning federal entities and income.
Dobbins v. Erie County
Date: March 4, 1842
Citation: 41 U.S. 435
Issue: State taxation
Significance: In this important example of the nineteenth century view of federalism, the Supreme Court ruled that a state could not tax a person’s federal income.
A U.S. ship captain on duty in Pennsylvania challenged the validity of that state’s tax on his federal income. The state supreme court upheld the tax, but the Supreme Court unanimously reversed its decision, holding that such a tax would infringe on the taxing power of the national government.
Dobbins is historically significant as an example of the nineteenth century view of federalism. It followed Chief Justice John Marshall’s landmark decision in McCulloch v. Maryland (1819) by interpreting the parallel immunities of both the federal and state governments broadly so that neither could tax the other. It remained valid until indirectly overturned in Graves v. New York ex rel. O’Keefe (1939) and is no longer a valid legal principle.