102 U.S. 586 (1881), argued 8–9 Apr. 1880, decided 24 Jan. 1881 by vote of 7 to 0; Swayne for the Court, Hunt and Clifford not participating. At issue in Springer was the constitutionality of the 1862 income tax, enacted to help finance the Civil War. William M. Springer refused to pay the income tax on his professional earnings as an attorney. The federal government taxed land belonging to Springer, and the property was eventually sold to the United States for the amount of the unpaid tax. The government brought an action of ejectment against Springer, who argued that the income tax was an invalid direct tax not apportioned among the states according to population as prescribed by the Constitution.
Relying on historical evidence, Justice Noah H. Swayne determined that Congress had only treated taxes on real property and slaves as direct taxes. He accorded great weight to this “uniform practical construction of the Constitution” by Congress (p. 599). Swayne also emphasized the Supreme Court's decision in Hylton v. United States (1796), upholding a tax on carriages. He concluded that direct taxes included only capitation taxes and taxes on land, and hence the income tax was constitutional. The Civil War income tax remained in force until 1872.
The Springer decision was narrowly construed and distinguished by the Court in Pollock v. Farmers’ Loan & Trust Co. (1895), in which the justices invalidated the 1894 income tax as a direct tax not apportioned among the states. The authority of Congress to levy an income tax was not settled until the adoption of the Sixteenth Amendment in 1913.
James W. Ely, Jr.