Helvering v. Davis

Background

Intervening defendants, identified as the Commissioner and the Collector, filed a petition asking the Court to review the case. Their petition raised two specific questions about taxes imposed by the Social Security Act: one concerning the tax on employers under Section 804 and one concerning the tax on employees under Section 801. The Edison Electric Illuminating Company of Boston notified the Clerk that it joined the petition but did not take any further part in the proceedings. A writ asking the Court to take the case was issued.

Reasoning

The Court amended its earlier opinion to make clear what questions were presented for review. The revisions state explicitly that only two constitutional questions were before the Court: whether Congress had authority to impose the employer tax in Section 804, and whether the employee tax in Section 801 was properly at issue and, if so, within Congress’s authority. The Court also directed small textual changes, including striking the phrase "decree for an injunction" and substituting "equitable remedy" (a non-monetary court remedy), and changing the placement of the word "Petitioners" in the case title following the Edison Electric company’s name.

Real world impact

These amendments do not decide the constitutional questions themselves but clarify what the Court will decide on review. The clarified record narrows the legal questions that employers, employees, tax officials, and the named company can expect the Court to address. The opinion is reported as amended to reflect these specific edits and clarifications.