Lincoln v. United States

Background

Two American merchants sued to recover duties that had been taken from goods they shipped from New York to Manila between April 11, 1899 and October 25, 1901. The duties were collected under a President’s July 12, 1898 order issued during the war with Spain. By the time these goods arrived, the treaty with Spain had been ratified and Manila was held in U.S. possession, though there was later an insurrection declared by Aguinaldo in February 1899. Lower courts had dismissed the merchants’ claims and the merchants appealed.

Reasoning

The Court asked whether a wartime presidential order issued during the Spanish–American War could still authorize duties on imports from the United States to Manila after the treaty and while a local insurrection existed. The Court said the order was meant to govern wartime imports from foreign countries and did not apply to ports under United States title and possession like Manila. The Court relied on prior decisions holding that the insurrection did not make the islands a foreign country. It also found that a later act of Congress approving some presidential actions did not validate the particular collections at issue. As a result, the Court reversed the lower courts’ judgments.

Real world impact

The ruling means the merchants may pursue recovery of duties collected under the July 12, 1898 order and limits the Government’s claim that wartime orders can tax imports to territory under U.S. possession. The decision clarifies that local insurrection does not automatically make a U.S.-held port a foreign port, and that presidential wartime measures are confined to the scope Congress and the war itself authorized.