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Marvel v. Merritt, Collector

• 1885 • 116 U.S. 11 • Waite Court
In Marvel v. Merritt, Collector, the Supreme Court of the United States was asked to decide whether a state tax imposed on a federal patentee was unconstitutional. The plaintiff, Marvel, was the holder of a federal patent for a machine used to make paper bags. The defendant, Merritt, was the Collector of Internal Revenue for the state of New York. Merritt had imposed a tax on Marvel's patent, which Marvel argued was unconstitutional. The Supreme Court held that the tax was unconstitutional....Open Case
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Chief Waite Court
Term: 1885
Docket: 72
116 U.S. 11
6 S. Ct. 207
29 L. Ed. 550
1885 U.S. LEXIS 1884
Argued: Nov 23, 1885

Marvel v. Merritt, Collector

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Opinion Summary
AI Abstract

In Marvel v. Merritt, Collector, the Supreme Court of the United States was asked to decide whether a state tax imposed on a federal patentee was unconstitutional. The plaintiff, Marvel, was the holder of a federal patent for a machine used to make paper bags. The defendant, Merritt, was the Collector of Internal Revenue for the state of New York. Merritt had imposed a tax on Marvel's patent, which Marvel argued was unconstitutional. The Supreme Court held that the tax was unconstitutional. The Court reasoned that the patent was a federal right, and that the state could not interfere with the federal government's exclusive power to grant patents. The Court also noted that the tax was a burden on the patentee, and that it would discourage inventors from seeking patents. The Court concluded that the tax was unconstitutional, and that the state of New York could not impose a tax on a federal patentee. This decision established the principle that states cannot interfere with the federal government's exclusive power to grant patents.

Dissent Summary
AI Abstract

In Marvel v. Merritt, Collector, the Supreme Court was tasked with determining whether a state tax on national bank notes constituted an unconstitutional burden on interstate commerce. The majority opinion held that it did not and upheld the state's right to impose such taxes; however, Justice Field dissented from this decision. He argued that since Congress had exclusive authority over banking matters under Article I of the Constitution, any attempt by a State to interfere with those powers would be in violation of federal law and thus unconstitutional. Furthermore, he noted that while states have some power to regulate their own internal affairs they cannot do so at the expense of other States or interfere with congressional legislation regarding interstate commerce. As such, Justice Field concluded that imposing taxes on national bank notes was an impermissible interference in Congressional authority and should be struck down as unconstitutional

Opinion written by Justice SMatthews
Decided: Dec 14, 1885
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