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Constitutional Law Keyed to Levinson
Downes v. Bidwell
Citation:
182 U.S. 244 (1901)Facts
Downes (Petitioner), a merchant in San Juan, was a shipper of oranges from Puerto Rico to New York. When Puerto Rico became a U.S. territory, Congress had established sources of income for the territory, including duties on Puerto Rican goods like oranges imported into the United States. Downes challenged the enforcement of the tax, arguing that the duties violated Article I, § 8, cl.1 of the Constitution. This clause, one of the Constitution’s revenue clauses, states that “all duties, imposts, and excises shall be uniform throughout the United States.” Bidwell (Defendant) was the government agent responsible for collecting the duties.
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