McCulloch v Maryland

McCulloch v. Maryland is one of the most important Supreme Court cases in US history. It helped shape what the United States government looks like today by reaffirming the supremacy clause of the Constitution. It also set a precedent in how balancing power between the federal government and states.

Figure 1. United States Supreme CourtAuthor, Beyond my Ken, CC-BY-SA Wikimedia Commons

McCulloch v. Maryland Summary

The case has its origins in 1789 when the creation of a national bank was first proposed. This proposal sparked a Federalist vs. Anti-Federalist debate in Congress. The federalists won the debate, and the First Bank of the United States was chartered. However, after 20 years, Congress declined to renew its charter due to the same anti-federalist sentiment from years past.

Following the War of 1812, the discussion of creating a federal bank surfaced again and in 1816 Congress voted to create the Second Bank of the United States. Its charter angered many states because of its broader powers and influence than the First Bank of the United States. Maryland was particularly upset when a Second Bank of the United States branch opened up in Baltimore. The state created a law directly aimed at the federal bank; it would charge a $15,000 tax to any bank not charted by the state and the only bank not charted by the state in Maryland was the Second Bank of the United States.

Maryland attempted to collect its tax; however, James McColluch, a bank cashier, declined to pay it, calling the tax unconstitutional. Maryland sued McColluch and argued that Congress chartering a federal bank was unconstitutional and that as a state entity, it could collect from any business that conducted business within the state.

This case made its way to the Supreme Court in 1819. The Court unanimously sided with McCulloch. Chief Justice John Marshall authored the Court’s opinion. He explained that the chartering of a federal bank by Congress was constitutional because it was a power implied by its enumerated powers in the Constitution, citing theNecessary and Proper Clausein Article 1 of the Constitution. The Court also ruled that the Maryland tax was unconstitutional because, as a state entity, its actions cannot interfere with the federal government’s powers, citing theSupremacy Clausein Article 6 of the Constitution.

The decision made by the Supreme Court helped broaden federal powers while establishing the supremacy of the federal government over the states.

McCulloch v. Maryland Background

亚历山大•汉密尔顿Treasur的第一书记y and an avid proponent of Federalism led an effort for Congress to create a federal bank. He argued that a federal bank would stabilize the economy, issue money, hold public funds, collect tax revenues, and pay government debts. Critics with strong Anti-federalist views, including prominent figures Thomas Jefferson and James Madison, argued that the bank would create a monopoly and undermine state banks and that the Constitution did not give Congress the authority to charter federal banks. Once put to the vote, Hamilton prevailed, and in 1791, President George Washington signed a bill creating the first federal bank: The First Bank of the United States.

Figure 2. First Bank of the United States in Philadelphia in 1800, W. Birch & Son, CC-PD-Mark, Wikimedia Commons

The First Bank of the United States opened in Philadelphia before opening multiple locations around the United States. It was a public-private institution with the federal government owning 2 million in shares and private investors owning 8 million. Many still argued against its creation, and when it was up for renewal in 1811, Congress, under the Presidency of James Madison, decided not to renew it by one vote.

Creation of the Second Bank of the United States

Following the War of 1812, the United States government was heavily indebted; John Jacob Astor, a private sector magnate, and Representative John C. Calhoun led a movement to create a second federal bank. After years of debate, in 1816, Congress, under the same James Madison Presidency, voted in favor of establishing the Second Bank of the United States. As with the First Bank of the United States before it, the Second Bank of the United States opened in Philadelphia and went on to establish an additional 26 branches around the country. It provided ample credit to farmers and businesses and financed the shipping of goods in domestic and foreign markets. Due to its extensive presence and influence, the federal bank was able to control interest rates given by banks nationwide.

Many states were angered by this federal influence and resented the Second Bank of America’s overreach. Maryland, in 1818, run by the Democratic-Republican Party, passed a law that would impose a $15,000 tax on any bank not chartered by the state. This law was meant to take aim at the federal bank since it was the only bank not chartered by the state.

McCulloch and the Maryland Tax

Maryland moved forward to collect its tax from the Second Bank of the United States. However, there was an issue at the Baltimore Branch. The bank’s administrator, James McCulloch, refused to pay the tax and argued that the tax was unconstitutional. Maryland sued McCulloch, proclaiming that as a state entity, it could tax anyone doing business within the state and that Congress did not have the power to create a national bank. The state court voted in favor of Maryland, as did the Court of appeals. McColloch, represented by Daniel Webster, appealed his case to the Supreme Court. In 1819 the Supreme Court Heard his case.

Figure 3. Chief Justice Marshall - McCulloch v. Maryland 1819, Swatjester, CC-BY-SA-2.0, Wikimedia Commons

McCulloch v. Maryland Decision

In a unanimous decision by the Supreme Court, the Court ruled in favor of McCulloch. In the opinion written by Chief Justice Marshall, using many of Daniel Webster’s arguments, he states that the Second Bank of the United States was constitutional and that the Maryland tax was unconstitutional.

Regarding the constitutionality of a federal bank, Chief Justice Marshall refers to theNecessary and Proper Clauseof, Article 1, Section 8 of the Constitution. This clause allows the federal government to create and pass laws that are not specifically provided by the Constitution so long as those laws are "necessary and proper" to exercise the powers authorized to Congress in the enumerated powers of the Constitution. Because the enumerated powers allowed forregulating commerce, paying debts, and borrowing money, Marshall determined that the establishment of a federal bank was an implied power, that is, one which is not specifically listed but aids in the facilitation of exercising enumerated powers.

Regarding Maryland’s tax, the Chief Justice referred to theSupremacy Clausein Article 6 of the Constitution, which states that federal laws trump state laws. He argued that if a state could tax one federal entity, what would stop states from taxing any other federal entities. Maryland was threatening the superior laws of the United States and the Supreme Court decided that states had no right to interfere in federal law, making Maryland’s tax unconstitutional. But it didn’t stop there. The Court argued that the Maryland tax infringed on constitutional sovereignty because it levied a tax against all people in the United States when the state is only accountable for a portion of that population.

McCulloch v. Maryland Application towards the States

The McCulloch v. Maryland decision solidified the rule that federal laws trumped state laws. From this point on, states could not interfere in federal matters when the federal government used its implied powers to facilitate its constitutionally enumerated powers.

McCulloch v. Maryland Significance

The Court’s unanimous decision in McCulloch v. Maryland profoundly impacted the United States Government and played a significant role in defining what Federalism would look like in the United States. The decision broadened the powers of Congress by setting the precedent that Congress is within its rights to pass any law, as long as it aids its duties enumerated in the Constitution. It also firmly established that federal laws always supersede state laws and that states didn’t have the ability to interfere in federal laws, as demonstrated by theSupremacy Clausein the Constitution.

The implied powers of Congress have paved the way for income tax laws, immigration laws, gun laws, and draft laws, to name a few. Many critics, even today, argue that this case expanded the federal government’s powers to an unmeasurable level; implied powers can evolve and change over time, giving the federal government unconstrained power. These same critics also argue that the United States has slowly become an administrative state, tracing part of this problem back to the decision made in McCulloch v. Maryland.

Figure 4. United States Capitol, Place where Congress Meets, Martin Falbisoner, CC-BY-SA-3.0, Wikimedia Commons

McCulloch v. Maryland Facts

• In 1816 Congress chartered the Second Bank of the United States.
• The Second Bank of the United States opened multiple branches, including one in Baltimore, Maryland.
• Upset at the federal bank’s overreach, Maryland imposed a 15,000 tax on banks not chartered by the state. The only bank not chartered by the state was the Second Bank of the United States.
• James McCulloch, the cashier at the Second National Bank, refused to pay the tax, calling it unconstitutional.
• Maryland sues McCulloch, citing that they can collect taxes from anyone doing business within their state and that the federal bank was unconstitutional. The case ends up in Supreme Court.
• The Supreme court unanimously sides with McCulloch. Chief Justice Marshall authored the opinion and established that theNecessary and Proper Clauseallows Congress to charter a bank as part of its implied power. Since the bank was constitutional, the state had no power to tax according to theSupremacy Clause.
• 麦卡洛克马里兰州的意义it broadened Congress’s powers by allowing it to have implied powers when those powers assisted in carrying out its enumerated powers. And it firmly defined that federal government acts and regulations superseded state laws.