Downes v. Bidwell: The Background
Downes v. Bidwell is a Landmark Supreme Court Case that, in addition to several other Supreme Court cases, made up what is known as the Insular Cases. Rendered in the first several years of the twentieth century, these famous cases determined that full constitutional rights were not necessarily granted to individuals living in American territories.
Downes v. Bidwell is regarded as one of the most prominent insular cases. In this matter, the United States Supreme Court established that the United States of America was not just a nation of states and territories, but a nation of states and potentially permanent territories. Although the nation had always possessed territories, they were perpetually assumed to be transitional phases as areas under the sovereignty of the United States.
The case of Downes v. Bidwell was a landmark case in which the United States Supreme Court decided whether territories were subject to the protections and provisions offered under the Constitution of the United States. The resulting decision in Downes v. Bidwell narrowly held that the Constitution of the United States did not necessarily apply to territories. Instead, the congress of the United States maintained jurisdiction to create laws within territories in certain circumstances, including revenue that would not be allowed by the Constitution for proper states within the union.
Downes v. Bidwell: Background
The case of Downes v. Bidwell specifically concerned a merchant named Samuel Downes. Mr. Downes owned the S.B. Downes & Company which imported oranges into the port of New York from the newly acquired territory of Puerto Rico. Downes was required to pay import duties on these goods. In response, he sued George Bidwell, who was the customs inspector for the port of New York, on the grounds that as a territory of the United States, such duties fell under the jurisdiction of article 1, Section 8 of the United States Constitution which provides that all imposts, duties and excises must be uniform throughout the nation. Since this particular duty on oranges did not exist for other parts of the United States, he argued that it should not be placed for Puerto Rican goods.
Downes v. Bidwell: The Decision
The United States Supreme Court decided, in a five to four decision, that newly annexed territories were not officially part of the United States for purposes of the United States Constitution in the matter of administrative matters and revenues. However, the Court noted that the Constitutional rights guaranteed were applicable to all. Territories were therefore due the full protections of the United States Constitution only when the US Congress incorporates them as an essential part of the nation.