Downes v. Bidwell

Downes (plaintiff) paid, under protest, a tax imposed under the Foraker Act on goods shipped to him from Puerto Rico, and sued the New York tax collector (defendant), arguing that once the U.S. acquired Puerto Rico by treaty after the Spanish-American War, it became part of the United States, so a tax applying only to Puerto Rican goods violated the Constitution's requirement that federal taxes be uniform nationwide. The lower court held the uniformity clause did not apply to Puerto Rico.