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In re State Tonnage Tax Cases, 79 U.S. 204, 1870 WL 12754, 20 L.Ed. 370, 20 L.Ed. 376, 12 Wall. 204

Facts

The State of Alabama enacted a revenue law in 1866 that imposed a tax of $1 per ton on steamboats and other watercraft operating in its navigable waters. The plaintiffs, who were citizens of Alabama and owned several steamboats, were assessed this tax based on the tonnage of their vessels. They paid the tax under protest and subsequently filed suit to recover the amount, arguing that the tax was illegal as it violated the Constitution's prohibition against states levying tonnage duties without Congressional consent.

Under this act, one Lott, tax collector of the State of Alabama, demanded of Cox, the owner of the Dorrance, a steamer of 321 tons, and valued at $5000, and of several other steamers, certain sums as taxes; and under an act of 1867, identical in language with the one of 1866, just quoted, demanded from the Trade Company of Mobile certain sums on like vessels owned by them; the tax in all the cases being proportioned to the registered tonnage of the vessel.

Issue

The main legal issue was whether the tax imposed by Alabama on steamboats based on their tonnage constituted a duty of tonnage, which is prohibited by the Constitution without the consent of Congress.

The main legal issue was whether the tax imposed by Alabama on steamboats based on their tonnage constituted a duty of tonnage, which is prohibited by the Constitution without the consent of Congress.

Rule

The Constitution prohibits states from levying any duty of tonnage without the consent of Congress, and while states can tax property, they cannot impose taxes on vessels as instruments of commerce based on tonnage.

Although taxes levied, as on property, by a State upon vessels owned by its citizens, and based on a valuation of the same, are not prohibited by the Federal Constitution, yet taxes cannot be imposed on them by the State ‘at so much per ton of the registered tonnage.’

Analysis

The court analyzed the nature of the tax imposed by Alabama, determining that it was levied based on the tonnage of the vessels rather than their value as property. This classification as a tonnage duty fell squarely within the prohibition of the Constitution, as it was assessed in a manner similar to duties imposed by Congress on vessels engaged in commerce. The court emphasized that the tax was not merely a property tax but specifically targeted the vessels' capacity for commerce.

The court analyzed the nature of the tax imposed by Alabama, determining that it was levied based on the tonnage of the vessels rather than their value as property.

Conclusion

The U.S. Supreme Court concluded that the tax was unconstitutional and reversed the judgment of the Alabama Supreme Court, stating that the tax was effectively a duty of tonnage and thus invalid under the Constitution.

The U.S. Supreme Court concluded that the tax was unconstitutional and reversed the judgment of the Alabama Supreme Court.

Who won?

The plaintiffs prevailed in the case as the U.S. Supreme Court ruled that the tax was unconstitutional, reinforcing the principle that states cannot impose tonnage duties without Congressional consent.

The plaintiffs prevailed in the case as the U.S. Supreme Court ruled that the tax was unconstitutional, reinforcing the principle that states cannot impose tonnage duties without Congressional consent.

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