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Steamboat Company v. The Collector is a United States Supreme Court case from 1873. The case involved a dispute between the Steamboat Company and the Collector of Customs in the Port of New York. The Steamboat Company had been assessed a duty on goods imported from abroad, and the Collector had refused to refund the duty. The Steamboat Company argued that the duty was not legally due, and that the Collector had no authority to collect it. The Supreme Court held that the Collector had the authority to collect the duty, and that the Steamboat Company was not entitled to a refund. The Court reasoned that the duty was imposed by Congress, and that the Collector was acting within his authority in collecting it. The Court also held that the Steamboat Company had failed to prove that the duty was not legally due. The decision of the Supreme Court was that the Collector was entitled to collect the duty, and that the Steamboat Company was not entitled to a refund. This decision established the principle that the Collector of Customs has the authority to collect duties imposed by Congress, and that the burden of proof is on the taxpayer to prove that the duty is not legally due.
Justice Field delivered the dissenting opinion in this case. He argued that the tax imposed by Congress was unconstitutional because it violated the due process clause of the Fifth Amendment, which states that no person shall be deprived of life, liberty or property without due process of law. The tax was a direct burden on steamboat companies and their passengers as they had to pay an additional fee for using navigable waters within U.S. jurisdiction; thus, it constituted a deprivation of property without due process since there was no opportunity for them to challenge its legality before being required to pay it. Furthermore, Justice Field noted that while Congress has broad powers over interstate commerce and navigation under Article I Section 8 Clause 3 (the Commerce Clause), these powers do not extend so far as to allow taxation on vessels navigating within state boundaries where such taxation would interfere with local laws or regulations concerning navigation and trade between different parts of one state - something he believed this particular tax did indeed do in violation of both federalism principles and constitutional limits on congressional power set out in Article I Section 10 Clause 2 (the Import-Export Clause).