16 Pet. (41 U.S.) 435 (1842), argued 14 Feb. 1842, decided 4 Mar. 1842 by vote of 9 to 0; Wayne for the Court. In Dobbins, the captain of a United States revenue cutter stationed in Pennsylvania challenged the validity of that state's taxation on the income derived from his office. The United States Supreme Court, reviewing a decision by the Pennsylvania Supreme Court upholding the validity of the tax, unanimously reversed, holding that “the unconstitutionality of such taxation by a state as that now before us may be safely put—though it is not the only ground—upon its interference with the constitutional means which have been legislated by the government of the United States to carry into effect its powers to lay and collect taxes, duties, imposts, etc., and to regulate commerce” (p. 449). Dobbins's classic formulation of the principle that the state governments cannot lay a tax upon the constitutional means employed by the federal government to execute its constitutional powers was implicitly overruled by the Supreme Court's 1939 decision in Graves v. New York.
Dobbins was an important case in a line of nineteenth-century Supreme Court precedents, beginning with Chief Justice John Marshall's opinion in McCulloch v. Maryland (1819), interpreting the doctrine of intergovernmental immunities broadly. This doctrine holds that the federal and state governments possess some degree of reciprocal immunity from each other's taxing and regulatory powers. It has been sharply curtailed in its scope since the mid-1930s by the Court. Dobbins thus is no longer good law.
Robert A. Williams