The Constitution of the United States of America: Analysis and Interpretation: Annotations of Cases Decided by the Supreme Court of the United States to June 30, 1952
History
The Constitution of the United States of America: Analysis and Interpretation: Annotations of Cases Decided by the Supreme Court of the United States to June 30, 1952
Constitutional law -- United States; Constitutions -- United States
It results that the power of
Congress to authorize expenditure of public moneys for public purposes
is not limited by the direct grants of legislative power found in the
Constitution."[288]
The Security Act Cases
Although holding that the spending power is not limited by the specific
grants of power contained in article I, section 8, the Court found,
nevertheless, that it was qualified by the Tenth Amendment, and on this
ground ruled in the Butler case that Congress could not use moneys
raised by taxation to "purchase compliance" with regulations "of matters
of State concern with respect to which Congress has no authority to
interfere."[289] Within little more than a year this decision was
reduced to narrow proportions by Steward Machine Co. _v._ Davis,[290]
which sustained the tax imposed on employers to provide unemployment
benefits, and the credit allowed for similar taxes paid to a State. To
the argument that the tax and credit in combination were "weapons of
coercion, destroying or impairing the autonomy of the States," the Court
replied that relief of unemployment was a legitimate object of federal
expenditure under the "general welfare" clause; that the Social Security
Act represented a legitimate attempt to solve the problem by the
cooperation of State and Federal Governments; that the credit allowed
for State taxes bore a reasonable relation "to the fiscal need subserved
by the tax in its normal operation,"[291] since State unemployment
compensation payments would relieve the burden for direct relief borne
by the national treasury. The Court reserved judgment as to the validity
of a tax "if it is laid upon the condition that a State may escape its
operation through the adoption of a statute unrelated in subject matter
to activities fairly within the scope of national policy and
power."[292]
Earmarked Funds
The appropriation of the proceeds of a tax to a specific use does not
affect the validity of the exaction, if the general welfare is advanced
and no other constitutional provision is violated. Thus a processing tax
on coconut oil was sustained despite the fact that the tax collected
upon oil of Philippine production was segregated and paid into the
Philippine Treasury.[293] In Helvering _v._ Davis,[294] the excise tax
on employers, the proceeds of which were not earmarked in any way,
although intended to provide funds for payments to retired workers, was
upheld under the "general welfare" clause, the Tenth Amendment being
found to be inapplicable.
Conditional Grants-in-Aid
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