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The Head Money Cases, 112 U.S. 580 (1884),[1] also referred to as Edye v. Robertson, were a group of cases decided together by the United States Supreme Court.

Head Money Cases
Seal of the United States Supreme Court
Argued November 19–20, 1884
Decided December 8, 1884
Full case nameEdye and Another v. Robertson, Collector; Cunard Steamship Company v. Robertson; Same v. Same
Citations112 U.S. 580 (more)
5 S. Ct. 247; 28 L. Ed. 798; 1884 U.S. LEXIS 1909; 3 A.F.T.R. (P-H) 2473
Case history
PriorOn writs of error from the Circuit Courts of the Eastern and Southern Districts of New York
The Court established the precedent that treaties do not hold a privileged position above other acts of Congress, and other laws affecting "its enforcement, modification, or repeal" are legitimate.
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
MajorityMiller, joined unanimously
Laws applied
U.S. Const.


Pursuant to the Immigration Act of 1882, officers from the customhouse in the Port of New York began collecting a tax from ships of fifty cents for each immigrant on board who arrived at Ellis Island. Multiple ship owners sued because they were transporting Dutch immigrants, and the Netherlands had a treaty with the United States that seemed to prohibit the tax.


The case established the precedent that treaties, which are described in the Supremacy Clause of the US Constitution as "the supreme law of the land" equal to any domestic federal law, do not hold a privileged position above other acts of Congress. Hence, other laws affecting the "enforcement, modification, or repeal" of treaties are legitimate.

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