This section contains the nature of the case and procedural background.

Congress passed a law that taxed carriages. D, who was subject to the tax claimed that a tax on carriages, is a direct tax, and, therefore, by the constitution, must be laid according to the census, directed by the constitution to be taken, to ascertain the number of Representatives from each State. D claimed that the tax on carriages, is not laid by that rule of apportionment, but by the rule of uniformity, prescribed by the constitution, in the case of duties, imports, and excises; and a tax on carriages, is not within either of those descriptions. P sued D. D confessed judgment and appealed.

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