Hylton v. United States

Hylton v. United States
Supreme Court of the United States
Argued February 23, 1796 Decided March 8, 1796
Full case name	Daniel Hylton, Plaintiff in Error v. the United States
Citations	3 U.S. 171 (more) 3 Dall. 171; 1 L. Ed. 556; 1796 U.S. LEXIS 397; 2 A.F.T.R. (P-H) 2155
Case history
Prior	Defendant convicted, Circuit Court for the District of Virginia
Subsequent	None
Holding
A tax on the possession of goods is not a "direct" tax, which must be apportioned under Article I of the Constitution.
Court membership
Chief Justice Oliver Ellsworth Associate Justices James Wilson · William Cushing James Iredell · William Paterson Samuel Chase
Case opinions
Seriatim	Chase
Seriatim	Paterson
Seriatim	Iredell
Seriatim	Wilson
Ellsworth and Cushing took no part in the consideration or decision of the case.
Laws applied
U.S. Const. art. I; An Act laying duties upon Carriages for the conveyance of Persons

Hylton v. United States, 3 U.S. (3 Dall.) 171 (1796),^[1] is an early United States Supreme Court case in which the Court held that a yearly tax on carriages^[2] did not violate the Article I, Section 2, Clause 3 and Article I, Section 9, Clause 4 requirements for the apportioning of direct taxes. The Court concluded that the carriage tax was not a direct tax, which would require apportionment among the states. The Court noted that a tax on land was an example of a direct tax that was contemplated by the Constitution.

The case is also significant for being the first case by the Supreme Court to rely on judicial review, later formally established by Marbury v. Madison (1803), to decide whether a statute of Congress was unconstitutional.^[3]