People v. Allen, 42 N.Y. 486 (1870)
When interpreting constitutional language, courts should give words their ordinary and popularly understood meaning unless the context clearly indicates a different, technical sense was intended by the framers.
Summary
This case concerns the interpretation of the term “canal revenues” within the context of the New York State Constitution of 1846. The central issue was whether a tax imposed on merchandise carried by railroad companies should be considered part of the dedicated “canal revenues” under Article 7 of the constitution, thus preventing the legislature from repealing that tax. The court held that “canal revenues” referred solely to income derived directly from the State canals (tolls, water rents, etc.) and not to auxiliary taxes or fees, affirming the legislature’s power to repeal the tax on railroads. The court emphasized interpreting the Constitution according to the plain meaning of the words used, considering the context and purpose of the provision.
Facts
The New York Constitution of 1846 contained provisions (Article 7) directing how “canal revenues” were to be used, primarily for paying canal debt. Laws had been enacted imposing a tax on merchandise transported by railroad companies, arguably as a substitute for canal tolls, to protect canal revenue. In 1851, the legislature repealed these laws, eliminating the tax on railroad merchandise. The plaintiffs argued that the tax was a form of “canal revenue” that the legislature couldn’t repeal due to the constitutional provisions.
Procedural History
The case originated from a challenge to the 1851 law repealing the railroad tax. The lower courts upheld the repeal. The case then went to the New York Court of Appeals.
Issue(s)
Whether the toll or tax imposed by laws on merchandise carried by railroad companies at the time of the adoption of the Constitution was included within the term “canal revenues” as appropriated by Article 7 of that instrument, thus restricting the legislature’s power to repeal that tax.
Holding
No, because the term “canal revenues,” as used in the Constitution, refers only to revenues directly derived from the operation of the State canals themselves (tolls, rents for surplus water, etc.) and does not encompass taxes imposed on other industries, even if those taxes were initially intended to benefit the canals.
Court’s Reasoning
The court based its decision on several key principles of constitutional interpretation. First, the court emphasized that the words in a constitution should be understood in their “plain, obvious and common sense.” Quoting Chief Justice Marshall, the court noted that the framers “must be understood to have employed words in their natural sense, and to have intended what they said.” The court reasoned that “revenues of the canals” naturally refers to the direct income from the canals themselves. The court found no ambiguity in the language, precluding the need to resort to external sources of interpretation. The court also examined the context of Article 7, noting that provisions regarding expenses of collection and repairs clearly referred only to the canals themselves. The court highlighted that the framers of the Constitution distinguished between “canal revenues” and “auxiliary funds,” implying that the railroad tax belonged to the latter category. The court rejected the argument that the Constitution of 1821 restricted the legislature from taking any action that might divert trade from the canals. It found no clearly expressed intent to cripple the legislature’s power to develop the state’s resources and attract commerce. Finally, the court noted that the legislature retained “uncontrolled discretion over the tolls” of the canals, suggesting a lack of intent to rigidly protect canal revenue at all costs. The court stated, “There is, then, nothing in the provisions of the act, or in the language or terms in which these provisions are embodied, to give countenance to the idea that these tolls were in any sense regarded as ‘canal revenues.’”