Hylton v. United States
Hylton v. United States (1796) is a significant Supreme Court case that addressed the constitutionality of a congressionally enacted carriage tax. In this case, Daniel Hylton argued against the tax, claiming it was an unconstitutional direct tax. The justices involved—Samuel Chase, William Paterson, and James Iredell—wrote separate opinions but collectively concluded that the tax was constitutional, labeling it as an indirect tax, which does not violate Article I of the U.S. Constitution. The case is noteworthy because it implied the Court's ability to exercise judicial review, a power that would later be more explicitly asserted in the landmark case of Marbury v. Madison. Although judicial review was not explicitly stated in the Constitution, Hylton v. United States contributed to the early understanding and establishment of this judicial power. The implications of this case continue to resonate in discussions regarding the scope and limits of congressional power and taxation.
Hylton v. United States
Date: March 8, 1796
Citation: 3 U.S. 171
Issues: Judicial review; taxing and spending clause
Significance: The Supreme Court’s agreement to hear a case in which it was asked to review the constitutionality of a tax levied by Congress is regarded as implying that the Court had the power of judicial review.
Marbury v. Madison (1803) is generally accepted as the first case in which the Supreme Court both asserted its power of judicial review and used that power to strike down a congressional enactment. Because judicial review is not explicitly mentioned in the Constitution, the Court’s argument was, in part, that it was so widely understood that the Court was to have that power that no specific mention was necessary. Later legal experts have searched for evidence of this claim before Marbury. This evidence can be found in Hylton and Hayburn’s Case (1792).
Daniel Hylton defended himself for nonpayment of a congressionally enacted carriage tax, asserting it was an unconstitutional direct tax and, in effect, asking the Court to use the power of judicial review to declare the tax unconstitutional. Justices Samuel Chase, William Paterson, and James Iredell all wrote seriatim (separate) opinions but agreed the tax was constitutional because it was indirect and therefore not prohibited by Article I of the U.S. Constitution. They were the only justices available to hear the case, but their agreeing to hear the case implied that the Court had the power of judicial review.