Head Money Cases Explained

Litigants:Head Money Cases
Arguedatea:November 19
Arguedateb:20
Argueyear:1884
Decidedate:December 8
Decideyear:1884
Fullname:Edye and Another v. Robertson, Collector; Cunard Steamship Company v. Robertson; Same v. Same
Usvol:112
Uspage:580
Parallelcitations:5 S. Ct. 247; 28 L. Ed. 798; 1884 U.S. LEXIS 1909; 3 A.F.T.R. (P-H) 2473
Prior:On writs of error from the Circuit Courts of the Eastern and Southern Districts of New York
Holding:Treaties do not hold a privileged position above other acts of Congress, and other laws affecting their "enforcement, modification, or repeal" are legitimate.
Majority:Miller
Joinmajority:unanimously
Lawsapplied:U.S. Const.

The Head Money Cases, 112 U.S. 580 (1884), also referred to as Edye v. Robertson, were a group of cases decided together by the United States Supreme Court.

Background

Pursuant to the Immigration Act of 1882, officers from the customhouse in the Port of New York began collecting a tax from ships of fifty cents for each immigrant aboard. Multiple ship owners sued because they were transporting Dutch immigrants, and the Netherlands had a treaty with the United States that seemed to prohibit the tax.

Decision

The case established the precedent that treaties, which are described in the Supremacy Clause of the US Constitution as "the supreme law of the land" equal to any domestic federal law, do not hold a privileged position above other acts of Congress. Hence, other laws affecting the "enforcement, modification, or repeal" of treaties are legitimate.

See also

A similar case covering a head tax on British immigrants.