• Last updated on November 11, 2022

In this important example of the nineteenth century view of federalism, the Supreme Court ruled that a state could not tax a person’s federal income.

A U.S. ship captain on duty in Pennsylvania challenged the validity of that state’s tax on his federal income. The state supreme court upheld the tax, but the Supreme Court unanimously reversed its decision, holding that such a tax would infringe on the taxing power of the national government.FederalismState taxation;Dobbins v. Erie County[Dobbins v. Erie County]Federalism

Dobbins is historically significant as an example of the nineteenth century view of federalism. It followed Chief Justice John Marshall’s landmark decision in McCulloch v. Maryland[case]McCulloch v. Maryland[MacCulloch v. Maryland] (1819) by interpreting the parallel immunities of both the federal and state governments broadly so that neither could tax the other. It remained valid until indirectly overturned in Graves v. New York ex rel. O’Keefe[case]Graves v. New York ex rel. O’Keefe[Graves v. New York ex rel. O’Keefe] (1939) and is no longer a valid legal principle.

Collector v. Day

Graves v. New York ex rel. O’Keefe

Helvering v. Davis

McCulloch v. Maryland

Separation of powers

State taxation

Tax immunities

Categories: History Content