A tax on the possession of goods is not a direct tax that must be apportioned among the states according to their populations. This case featured the first example of judicial review by the Supreme Court. Decided March 8, 1796 (argued February 23, 1796). Topic: Federalism. Hylton v. United States, 3 U.S. 171 (1796), is an early United States Supreme Court case in which the Court held that a yearly tax on carriages did not violate the Article I, Section 2, Clause 3 and Article I, Section 9, Clause 4 requirements for the apportioning of direct taxes. The Court concluded that the carriage tax was not a direct tax, which would require apportionment among the states. The Court noted that a tax on land was an example of a direct tax that was contemplated by the Constitution. Wiki link