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Downes v. Bidwell

United States Supreme Court
182 U.S. 244 (1901)


Downes (plaintiff) paid a tax, under protest, on goods shipped to him from Puerto Rico. The tax was imposed under the federal Foraker Act, which created a civil government for Puerto Rico. Downes brought suit against the tax collector in New York (defendant), arguing that when the United States signed the treaty with Spain to end the Spanish–American War, Puerto Rico became a part of the United States. Accordingly, Downes claimed, the tax violated Article I, Section 8, of the Constitution, which required that congressional taxes be uniform throughout the country. The lower court held that this constitutional provision did not apply to Puerto Rico. The United States Supreme Court granted certiorari.

Rule of Law


Holding and Reasoning (Brown, J.)

Concurrence (White, J.)

Dissent (Harlan, J.)

Dissent (Fuller, C.J.)

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