In 1895, an attorney named Joseph H. Choate persuaded the U.S.
Supreme Court to declare an income tax approved by Congress unconstitutional.
Choate told the court that:
The act of Congress which we are impugning before you is communist
in its purposes and tendencies and is defended here upon principles
as communistic, as socialistic, what shall I call them, as populistic
as ever have been addressed to any political assembly in the
As a result of the court decision in the case of Pollock v.
Farmers' Loan and Trust Co., the United States did not institute
an income tax until the 16th Amendment was ratified in 1913.
Choate rested his arguments partly on ideas associated with Charles Darwin, who published his theory of evolution in 1859. Darwin had argued that within nature, there was a process of competition within and between species, and that, through a process of natural selection, the fittest organisms prevail. Closely associated with the English theorist Hebert Spencer (1820-1903) and the Yale sociologist William Graham Sumner (1840-1910), Social Darwinism sought to apply the Darwinian principles of survival of the fittest and the struggle of existence to economics, ethics, and other realms of life. Social Darwinists like Spencer believed that this theory of evolution gave scientific validity to the notion that government should keep its hands off the economy.
Critics of Social Darwinism, including John Dewey and William James, rejected the notion that the process of social and economic change should occur unregulated, arguing that government should intervene to address the social ills that accompanied industrial development.
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