Haavik v. Alaska Packers Assn.
Headline: Court upholds Alaska’s $5 annual poll tax and $5 nonresident fisherman license, allowing the territory to collect these taxes from nonresident crew members and let employers deduct them
Holding: The Court affirmed that Alaska’s territorial laws imposing a $5 poll tax and a $5 license on nonresident fishermen were valid and could be collected, including deductions from employers against workers’ wages.
- Allows Alaska to tax nonresident fishermen who work in its waters.
- Permits employers to pay and deduct these territorial taxes from workers’ wages.
- Affirms territorial power to favor local residents through tax rules.
Summary
Background
A man living in California worked as a seaman and fisherman for a shipping company and sailed to Alaska to fish from about mid-May to mid-September 1921. Alaska’s territorial legislature had passed two laws: a $5 annual poll tax on each male person for school funds and a $5 annual license tax on every nonresident fisherman, defined to include persons employed on fishing boats. The employer paid those taxes and deducted the amounts from the worker’s wages, and the worker sued to recover the deductions after lower courts upheld the statutes.
Reasoning
The Court asked whether Alaska’s territorial government had the power to impose those taxes and whether taxing this worker violated constitutional protections. Relying on the congressional law that set up Alaska’s government, the Court concluded the legislature had authority to tax persons actually within the territory. The Court noted the worker stayed in Alaska for several months and received local protection and services, so it was reasonable to require a contribution. The Court also said the license applied equally to nonresidents from any State and that favoring local residents in taxation was not forbidden by the Constitution.
Real world impact
The ruling means Alaska’s territorial tax laws could be enforced against nonresident fishermen who work in its waters, and employers may charge those taxes against wages. The decision affirms earlier federal appeals court rulings and upholds the territory’s power to prefer residents in tax rules. The decree of the lower court was affirmed.
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