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Salamanca Township v. Wilson

• 1883 • 109 U.S. 627 • Waite Court
In Salamanca Township v. Wilson, the Supreme Court of the United States was asked to decide whether a township had the authority to levy a tax on a non-resident landowner. The township argued that it had the authority to do so under the state constitution. The landowner argued that the tax was unconstitutional because it violated the Privileges and Immunities Clause of the Fourteenth Amendment. The Supreme Court held that the tax was unconstitutional because it violated the Privileges and...Open Case
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Chief Waite Court
Term: 1883
Docket: 919
109 U.S. 627
3 S. Ct. 344
27 L. Ed. 1055
1883 U.S. LEXIS 1003

Salamanca Township v. Wilson

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Opinion Summary
AI Abstract

In Salamanca Township v. Wilson, the Supreme Court of the United States was asked to decide whether a township had the authority to levy a tax on a non-resident landowner. The township argued that it had the authority to do so under the state constitution. The landowner argued that the tax was unconstitutional because it violated the Privileges and Immunities Clause of the Fourteenth Amendment. The Supreme Court held that the tax was unconstitutional because it violated the Privileges and Immunities Clause of the Fourteenth Amendment. The Court reasoned that the tax discriminated against non-residents by treating them differently than residents. The Court also noted that the tax was not necessary to support the township's government, and thus was not a valid exercise of the township's taxing power. The Court's decision in this case established that the Privileges and Immunities Clause of the Fourteenth Amendment protects non-residents from discriminatory taxation. This decision has been cited in numerous subsequent cases involving the taxation of non-residents.

Dissent Summary
AI Abstract

Justice Field delivered the dissenting opinion in Salamanca Township v. Wilson, arguing that the majority's decision was contrary to both precedent and reason. He argued that it was not necessary for a party to prove an actual injury or damage in order to bring suit under the Fourteenth Amendment; rather, he believed that any violation of rights secured by law should be sufficient grounds for bringing suit. Furthermore, Justice Field noted that even if there had been no actual damages suffered by either party, this did not mean they were without remedy as long as their constitutional rights had been violated. In conclusion, Justice Field maintained his belief that any person whose constitutional rights have been infringed upon has standing before a court of law and is entitled to relief from such infringement regardless of whether or not they can demonstrate an actual injury or damage resulting from said infringement.

Opinion written by Justice MRWaite
Decided: Dec 17, 1883
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