Gardner v. The Collector was a United States Supreme Court case that was decided in 1867. The case involved a dispute between the Collector of Customs in the Port of New York and the owner of a vessel, Gardner. Gardner had been charged with failing to pay the required duties on the vessel, and he argued that the Collector had no authority to impose the duties. The Supreme Court held that the Collector had the authority to impose the duties, and that the duties were valid. The Court reasoned that the Collector was acting within his authority under the Tariff Act of 1864, which authorized the imposition of duties on vessels entering the United States. The Court also held that the Collector had the authority to impose the duties, even if the vessel was owned by a foreign citizen. The decision in Gardner v. The Collector established that the Collector of Customs had the authority to impose duties on vessels entering the United States, regardless of the nationality of the owner. This decision has been cited in numerous subsequent cases involving the authority of the Collector of Customs.

In the case of Gardner v. The Collector, Justice Field delivered a dissenting opinion in which he argued that the tax imposed by Congress on distilled spirits was unconstitutional and violated the Fifth Amendment's protection against double taxation. He noted that while it is true that taxes may be levied for revenue purposes, they must still comply with constitutional limits. In this case, however, Congress had exceeded those limits by imposing an additional tax on already taxed property without any reasonable basis or justification for doing so. Furthermore, Field argued that such a law would create an unequal burden among citizens as some would have to pay more than others based solely on their occupation or business pursuits; thus violating both due process and equal protection under the law guaranteed by the Fourteenth Amendment. Ultimately then, Field concluded that if allowed to stand such legislation could lead to arbitrary government action and should therefore be struck down as unconstitutional.