The Supreme Court approved a statute allowing Congress to levy a head tax on immigrants, thereby establishing congressional power over immigration and taxes imposed for other purposes.
Early immigration was handled by the states, some of which imposed a head tax on every immigrant a shipper delivered to the United States to create a fund to alleviate immigrants in financial distress. The Supreme Court struck down these state laws as an interference with congressional power in the Passenger Cases
Commerce, regulation of
Taxing and spending clause