Springer V. United States - Rationale

Rationale

The Court set forth a lengthy examination of the history leading to the inclusion of the apportionment requirement in the Constitution:

It appears that on the 11th of July, in that year, there was a debate of some warmth involving the topic of slavery. On the day following, Gouverneur Morris, of New York, submitted a proposition 'that taxation shall be in proportion to representation.' It is further recorded in this day's proceedings, that Mr. Morris having so varied his motion by inserting the word 'direct,' it passed nem. con., as follows: 'Provided always that direct taxes ought to be proportioned to representation.' 2 Madison Papers, by Gilpin, pp. 1079-1081. On the 24th of the same month, Mr. Morris said that 'he hoped the committee would strike out the whole clause. . . . He had only meant it as a bridge to assist us over a gulf; having passed the gulf, the bridge may be removed. He thought the principle laid down with so much strictness liable to strong objections.' Id. 1197. The gulf was the share of representation claimed by the Southern States on account of their slave population. But the bridge remained. The builder could not remove it, much as he desired to do so. All parties seem thereafter to have avoided the subject. With one or two immaterial exceptions, not necessary to be noted, it does not appear that it was again adverted to in any way. It was silently incorporated into the draft of the Constitution as that instrument was finally adopted.

After further examining the contemporaneous writings of James Madison and Alexander Hamilton, the Court quoted Hamilton as asserting that direct taxes should be held to be only "capitation or poll taxes, and taxes on lands and buildings, and general assessments, whether on the whole property of individuals or on their whole real or personal estate. All else must, of necessity, be considered as indirect taxes". Comparing Hamilton's understanding of the clause to the facts of the case, the Court stated:

The tax here in question falls within neither of these categories. It is not a tax on the "whole . . . personal estate" of the individual, but only on his income, gains, and profits during a year, which may have been but a small part of his personal estate, and in most cases would have been so. This classification lends no support to the argument of the plaintiff in error.

The Court concluded that "whenever the government has imposed a tax which it recognized as a direct tax, it has never been applied to any objects but real estate and slaves", and ultimately held "that direct taxes, within the meaning of the Constitution, are only capitation taxes, as expressed in that instrument, and taxes on real estate; and that the tax of which the plaintiff in error complains is within the category of an excise or duty".