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The United States Supreme Court case of The United States v. Ellen E. White, Administratrix of Charles White, Deceased involved a dispute over the ownership and title to certain lands in the state of Missouri. At issue was whether or not an 1808 treaty between the Osage Nation and the United States government had extinguished Indian title to these lands prior to their purchase by Charles White from members of that tribe in 1833. The court ultimately held that it did not, ruling that “the right acquired by [Charles] White under his purchase is valid” as there was no evidence indicating any intention on behalf of either party at the time for such a transferral or extinguishment of rights to occur through this treaty agreement. As such, Ellen E. White (as administratrix) retained her claim against those who sought possession without legal authority over these properties belonging to her late husband's estate
In the United States v. Ellen E. White, Administratrix of Charles White, Deceased case, the Supreme Court was asked to decide whether a tax imposed by Congress on all legacies and distributive shares of personal property in cases where the deceased died without leaving a will is constitutional or not. The majority opinion held that it was unconstitutional as it violated Article I Section 9 Clause 4 which states that no capitation or other direct tax shall be laid unless in proportion to population. However, Justice Grier dissented from this opinion and argued that since there were no taxes imposed directly upon individuals but rather upon their estates after death then such taxation did not violate Article I Section 9 Clause 4 as they are indirect taxes instead of direct ones. He further argued that while Congress may have exceeded its authority with respect to certain aspects of the law such as imposing an unequal burden among different classes based on wealth then those issues should be addressed separately from determining constitutionality under Article I Section 9 Clause 4 which he believed had been satisfied here due to being an indirect tax instead of a direct one.