Hylton v. United States (1796)

Case: Hylton v. United States (decided $March\, 8\, 1796$ ) — whether a tax on the possession of goods (carriages) must be apportioned among states by population.
Holding: The carriage tax is not a direct tax; it does not need to be apportioned. This upheld the constitutionality of the 1794 carriage tax.
Significance: Clarifies the distinction between direct and indirect taxes; the broader note in the material links this to judicial review (formally established later by Marbury v. Madison in $1803$ ).

Congress passed a law on $June\, 6\, 1794$ imposing a tax of $16$ dollars on all carriages.
Daniel Hylton argued the carriage tax was a direct tax and thus unconstitutional if not apportioned by state population.
The Circuit Court for the District of Virginia was divided on the definition of direct taxation, leading to a writ of error and transfer to the Supreme Court.

Is the carriage tax a direct tax requiring apportionment by population of the states?

The Supreme Court, in a unanimous ruling, affirmed the Circuit Court's decision that the carriage tax is not a direct tax and is constitutional.
The justices decided seriatim (individual opinions): Samuel Chase, William Paterson, James Iredell, James Wilson; Chief Justice Oliver Ellsworth did not participate.

Justice Samuel Chase:
- Argued the carriage tax is an indirect tax because carriages are consumable goods; not subject to apportionment.
- Expressed that direct taxes are likely limited to capitation (poll tax) and land, though not judicially determining all boundaries.
Justice William Paterson:
- Acknowledged uniformity and indirect nature of taxes on expenses or consumption; apportionment should not be used; carriage tax is indirect.
Justice James Iredell:
- Carriage tax is not a direct tax because it cannot be apportioned; if not direct, it must be uniform; thus, the judgment should be affirmed.
Justice James Wilson:
- Agreed with the result; reaffirmed that the carriage tax is constitutional.

The 1794 tax targeted carriages; Hylton challenged its directness and the apportionment requirement.
The Circuit Court differed on direct taxation, prompting the Supreme Court to hear the case.
Oral argument occurred between $February\, 23\, 1796$ and $February\, 25\, 1796$ ; decision issued on $March\, 8\, 1796$ .

Carriage tax amount: $16$ dollars per carriage.
Law enacted: $June\, 6\, 1794$ .
Decision: $March\, 8\, 1796$ .
Judicial review reference: $1803$ (Marbury v. Madison) as the formalization point per the provided material.

Distinction established between direct taxes (e.g., capitation, land) and indirect taxes (e.g., taxes on consumption/expenses).
Indirect taxes are not required to be apportioned by state population.
The case contributed to the broader understanding of constitutional interpretation by the early Supreme Court; the later formalization of judicial review is attributed to Marbury v. Madison in $1803$ according to the material.