Head Money Cases

Head Money Cases
Supreme Court of the United States
Argued November 19–20, 1884 Decided December 8, 1884
Full case name	Edye and Another v. Robertson, Collector; Cunard Steamship Company v. Robertson; Same v. Same
Citations	112 U.S. 580 (more) 5 S. Ct. 247; 28 L. Ed. 798; 1884 U.S. LEXIS 1909; 3 A.F.T.R. (P-H) 2473
Case history
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.
Court membership
Chief Justice Morrison Waite Associate Justices Samuel F. Miller · Stephen J. Field Joseph P. Bradley · John M. Harlan William B. Woods · Stanley Matthews Horace Gray · Samuel Blatchford
Case opinion
Majority	Miller, joined unanimously
Laws applied
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

• Passenger Cases: A similar case covering a head tax on British immigrants.
• Henderson v. Mayor of New York
• List of United States Supreme Court cases, volume 112

External links

• Works related to Head Money Cases at Wikisource
• Text of Head Money Cases, 112 U.S. 580 (1884) is available from: Cornell Justia Library of Congress OpenJurist