Hilton & Another v. Merritt, Collector was a United States Supreme Court case that dealt with the issue of taxation. The case involved two individuals, Hilton and another, who were challenging the constitutionality of a tax imposed by the Collector of Internal Revenue. The tax was imposed on the sale of certain goods and services, and the plaintiffs argued that the tax was unconstitutional because it violated the due process clause of the Fifth Amendment. The Supreme Court ultimately ruled in favor of the Collector, finding that the tax was constitutional and did not violate the due process clause. The Court reasoned that the tax was a valid exercise of the government's power to tax, and that it was not an arbitrary or oppressive exercise of that power. The Court also noted that the tax was not so excessive as to be oppressive, and that it was not so unreasonable as to be unconstitutional. The Court thus held that the tax was constitutional and that the Collector was entitled to collect it.

Justice Field delivered the dissenting opinion in Hilton & Another v. Merritt, Collector. He argued that the tax imposed by Congress was not a direct tax as defined by the Constitution and should be treated as an excise or duty instead. He reasoned that since it was levied on income from property rather than directly on property itself, it did not qualify as a direct tax under Article I of the Constitution. Furthermore, he noted that if this were considered to be a direct tax then all taxes would fall into this category which would render Article I's requirement for apportionment useless and unconstitutional. Justice Field concluded his dissent by stating that Congress had acted within its authority when imposing this particular taxation scheme and therefore there should have been no interference with their decision from any court of law.