United States v. Allen

No. 887
Decided Filed Supreme Court of the United States
Disposition
reversed
full scope · Majority with one dissent
Scan to open on mobileScan to open on another device
Court
District Court of the United States for the Northern District of California
Filed
Decided
Judge
Me. Justice White
Posture
Judgment rendered in favor of plaintiff (Allen) after hearing on merits
Plaintiff in error (1)
United States
Mr. Assistant Attorney General Whitney
v.
Defendant in error (1)
Allen
Mr. L. E. Payson, Mr. J. F. Evam

Overview

The judgments of the District Court and Circuit Court of Appeals were reversed. The cause was remanded to the District Court with directions to enter judgment in favor of the United States, with costs. Justice Beckham dissented.

Case summary

This case involves a claim by Allen for drawback of duties on imported bituminous coal used as fuel on a U.S. steam vessel engaged in coasting trade. The drawback was originally authorized by the 1883 tariff act but omitted from the 1890 tariff act. Allen argued the second proviso of section 25 of the 1890 act continued the drawback. The District Court and Circuit Court of Appeals ruled in Allen's favor. The Supreme Court reversed, holding the 1890 act superseded the 1883 act, the specific coal drawback provision was omitted, and the second proviso did not preserve it. The Court applied strict construction against exemptions and resolved doubts against the claimant.

Abstract

A claimant sought drawback of duties on imported bituminous coal used as fuel on a U.S. steam vessel in coasting trade, arguing that a provision from an earlier tariff act was continued by a proviso in a subsequent tariff act despite its omission. The lower courts ruled in favor of the claimant, but the Supreme Court reversed, holding that the new act superseded the prior one, the specific drawback provision was intentionally omitted, and the proviso did not preserve it under strict construction against exemptions. The case was remanded with directions to enter judgment for the United States.

Opinion of the court

Majority
opinion
Me. Justice Whitejoined by Majority of Court
  • 1890 tariff act superseded 1883 act
  • Coal drawback provision omitted from 1890 act
  • Second proviso of section 25 did not preserve coal drawback
  • Exemptions must be strictly construed
  • Doubts resolved against claimant

Dissenting opinions

1
Dissenting Me. Justice Beckham

Jurisdiction

not challenged
Statutory basis
Writ of certiorari
Subject matter
Review of federal circuit court of appeals decision
Jurisdictional facts
  • Writ of certiorari allowed to review judgment of Circuit Court of Appeals for the Ninth Circuit

Procedural posture

Posture at trial
Judgment rendered in favor of plaintiff (Allen) after hearing on merits
Posture on appeal
Direct appeal via writ of certiorari
Preserved issues
  • Interpretation of tariff act provisions regarding drawback on bituminous coal

Legal categories

Business

Case record

Full case name
UNITED STATES v. ALLEN
Docket number
No. 887
Court
Supreme Court of the United States
Trial court
District Court of the United States for the Northern District of California
Trial court judge
Not specified
Filed
Decided
Opinion author
Me. Justice White
Opinion type
published
Precedential status
precedential
Judges on panel
Me. Justice WhiteMe. Justice Beckham

Issues & holdings

1
Issues raised
1
reversed
1
Holdings
Standard of review

de novo

Disposition rationale

The 1890 act superseded the 1883 act and omitted the specific coal drawback provision; the second proviso did not preserve it

Preservation

Issue preserved for review

Holdings of the court

Continuation of drawback for bituminous coal under 1890 tariff act
The right to drawback on bituminous coal was taken away by the 1890 tariff act
The 1890 act superseded the 1883 act, omitted the specific coal drawback provision, and the second proviso of section 25 did not preserve it; exemptions must be strictly construed against the claimant
Majority with one dissentbinding precedent

Statutory interpretation

2
Statute
Tariff act of October 1, 1890, section 25
Question
Whether second proviso continued drawback for bituminous coal from 1883 act
Court's reading
The proviso did not continue the coal drawback; the 1890 act superseded the 1883 act and omitted that provision
Canons applied
Strict construction of exemptionsRepeals by implication disfavored but possible when subsequent act covers whole subject
no legislative history
Statute
Tariff act of March 3, 1883
Question
Provision for drawback on bituminous coal used as fuel on steam vessels
Court's reading
This provision was in effect until superseded by 1890 act
no legislative history

Standards of review

  • Interpretation of tariff act provisions — de novo Statutory interpretation is reviewed de novo

Timeline

Procedural path

Tariff act enactedDrawback provision createdShipping act limits benefitsTariff act omits provisionCoal supplied as fuelCase submittedSupreme Court decides
6
Events
4,832
Days, incident to ruling
—
Span
factual eventcited in opinion

Tariff act of March 3, 1883 enacted, including provision for drawback on bituminous coal used as fuel on steam vessels in coasting or foreign trade

Created statutory basis for drawback claim

Interpretation of tariff act provisions
Congress
factual eventcited in opinion

Shipping act limited drawback benefits to vessels of the United States

Modified scope of drawback provision

Interpretation of tariff act provisions
Congress
factual eventcited in opinion

Tariff act of October 1, 1890 enacted, omitting specific drawback provision for bituminous coal

Key statutory change at issue

Interpretation of tariff act provisions
Congress
factual eventcited in opinion

Allen supplied bituminous coal as fuel to steamer Humboldt

Underlying transaction giving rise to drawback claim

Interpretation of tariff act provisions
Allen · Steamer Humboldt Ports in northern California
procedural eventcited in opinion

Case submitted to Supreme Court

Oral argument or submission date

Interpretation of tariff act provisions
Supreme Court supreme court
procedural eventcited in opinion

Supreme Court decision issued

Outcome: Reversed lower court judgments

Final disposition of appeal

Interpretation of tariff act provisions
Supreme Court supreme court

Facts & evidence

Incident

Date
February 1891
Location
Ports in northern California

Key facts

4 facts
  1. Defendant in error (Allen) supplied bituminous coal as fuel to steamer Humboldt, a U.S. vessel engaged in coasting trade
  2. Allen sought drawback of duty on imported coal under tariff act provisions
  3. Government officials declined to recognize right to drawback
  4. Allen sued United States in District Court to recover drawback amounts

Disputed questions

  • Whether drawback provision from 1883 act continued under 1890 act

Procedural history

6 steps
  1. Complaint filed in District Court
  2. Demurrer overruled (52 Fed. Rep. 515)
  3. Answer filed
  4. Hearing on merits resulted in judgment for Allen
  5. Circuit Court of Appeals for Ninth Circuit affirmed (15 U. S. App. 252)
  6. Writ of certiorari granted by Supreme Court

Evidence in the record

Documentary
  • Tariff act of March 3, 1883
  • Tariff act of October 1, 1890
  • Shipping act of June 19, 1886
  • Regulations promulgated by Secretary of the Treasury

Objects of relevance

Bituminous coal imported as fuel for steam vesselsSteamer Humboldt (U.S. vessel in coasting trade)

Policy considerations

  • Strict construction of tax exemptions to prevent erosion of revenue
  • Clarity in statutory drafting to avoid ambiguity in tariff laws

Authorities

Cited authorities (3)

Tracy v. Tuffly, 134 U. S. 206
appliedquotedprecedent
Cited for principle that repeals by implication occur when subsequent act covers whole subject
at 134 U. S. at 223 Speaking through Mr. Justice Harlan
Schurtz v. Cook, 148 U. S. 397
appliedprecedent
Cited for principle that exemptions must be strictly construed
Keokuk & Western Railroad v. Missouri, 152 U. S. 301
appliedprecedent
Cited for principle that exemptions must be strictly construed
at 152 U. S. at 306

Related cases (3)

Tracy v. Tuffly, 134 U. S. 206
precedent
Cited for principle that repeals by implication occur when subsequent act covers whole subject
Schurtz v. Cook, 148 U. S. 397
precedent
Cited for principle that exemptions must be strictly construed
Keokuk & Western Railroad v. Missouri, 152 U. S. 301
precedent
Cited for principle that exemptions must be strictly construed

Statutes

  • Tariff act of March 3, 1883, c. 121, 22 Stat. 488, 511
  • Tariff act of October 1, 1890, c. 1244, 26 Stat. 617, section 25
  • Shipping act of June 19, 1886, c. 421, 24 Stat. 81

Standards & doctrines

  • Strict construction of tax exemptions
  • Repeal by implication when later act covers whole subject

Legal principles applied

  • Exemptions from taxation must be strictly construed against claimant
  • Doubts in statutory interpretation resolved against party claiming exemption

Notable quotes

““While it is true that repeals by implication are not favored by the courts, it is settled that, without express words of repeal, a previous statute will be held to be modified by a subsequent one, if the latter was plainly intended to cover the whole subject embraced by both, and to prescribe the only rules in respect to that subject that are to govern.””
Majority opinion (quoting Tracy v. Tuffly) — Discussing repeal by implication in statutory interpretation
States key principle of statutory construction applied in case
Index terms84
Summary terms
Legal mechanisms
Various actions
Various actors
Legal concepts
Legal outcomes
Legal issues
Legal procedures
Legal remedies
Legal evidence
Legal arguments
Legal defenses
Legal penalties
Legal procedural steps
Geo locations
Judges
Attorneys
Procedural terms
Substantive offenses
Entities and documentation
Legal actions
Action type
reversed
Target
Judgments of District Court and Circuit Court of Appeals
Appealed from
Circuit Court of Appeals for the Ninth Circuit
Context
The Supreme Court reversed the lower court judgments that had granted drawback to Allen
Scope
full
Further instructions
Remanded to District Court with directions to enter judgment in favor of United States, with costs
Disposition vote
Majority with one dissent
Action type
remanded
Target
Cause to District Court
Appealed from
Supreme Court
Context
After reversal, case sent back to District Court for entry of judgment consistent with Supreme Court ruling
Scope
full
Further instructions
Enter judgment in favor of United States, with costs
Disposition vote
Majority with one dissent
Physical materials
Search facets
Parties
Judges
BeckhamWhite
Courts
Locations
Statutes cited
Practice areas
Other index terms