Liverpool, New York & Philadelphia Steamship Co. v. Commissioners of Emigration

Liverpool, New York & Philadelphia S. S. Co. v. Commissioners of Emigration
Supreme Court of the United States
Argued March 24–25, 1884 Decided January 5, 1885
Full case name	Liverpool, New York & Philadelphia S. S. Co. v. Commissioners of Emigration
Citations	113 U.S. 33 (more) 5 S. Ct. 352; 28 L. Ed. 899; 1885 U.S. LEXIS 1648
Court membership
Chief Justice Morrison Waite Associate Justices Samuel F. Miller · Stephen J. Field Joseph P. Bradley · John M. Harlan William B. Woods · Stanley Matthews Horace Gray · Samuel Blatchford
Case opinion
Majority	Matthews, joined by unanimous

Liverpool, New York & Philadelphia S. S. Co. v. Commissioners of Emigration, 113 U.S. 33 (1885), was a case decided by the United States Supreme Court, in which the Supreme Court held that courts should not prematurely determine a statute applies or does not apply to a given case based solely on pleadings and the text of the statue without considering the evidence. The Court further held that in cases where it is unclear whether an act applies, courts should not preemptively rule on the act's constitutionality, an early statement of ripeness doctrine.

Background

The plaintiff, Liverpool, New York & Philadelphia Steamship Company, had paid over 1,093,000 dollars to the Commissioners of Emigration of the State of New York. These payments, termed 'commutation moneys,' were fees collected per passenger under New York state laws concerning immigration. Believing these payments to be illegal under federal law, Liverpool, New York & Philadelphia Steamship Company sued the Commissioners of Emigration of the State of New York to demand repayment of the 'commutation moneys.'

The state of New York moved to dismiss the case based on a recently passed Act of Congress, which they argued legalized the collection of taxes on immigrants entering a state. The trial court agreed with the defendant and directed a verdict in favor of the state of New York without considering any other evidence. The plaintiff then appealed to the Supreme Court.

Decision

In a unanimous decision, the Supreme Court reversed the judgment and remanded the case for a new trial. The Court held that the trial court had erred by refusing to hear evidence and directing a verdict based solely on the pleadings and the Act of Congress, and ordered a new trial.

Impact

The decision is significant for its early statement of ripeness doctrine, which was developed further in Ashwander v. Tennessee Valley Authority. This standard holds that courts should not decide constitutional issues prematurely and should exhaust all other avenues beforehand.

See also

• List of United States Supreme Court cases, volume 113
• Head Money Cases
• Constitutional avoidance
• Ripeness

External links

• 113 33 Justia.com (full case)