Whitney Vs Robertson

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WHITNEY, et.al. vs.

ROBERTSON
124 U.S. 190 January 9, 1888
Facts
Whitney, a merchant intricately involved in the importation of sugar from the Dominican Republic to the
United States, initiated legal proceedings against Robertson, a Customs official within the United States.
The core contention of Whitney's case was his objection to the imposition of duties on his sugar imports,
rooted in his argument that the similarity between his product and sugar imported from the Hawaiian
Islands, which was granted duty-free status, should exempt him from such duties. Central to Whitney's
argument was a treaty between the United States and the Dominican Republic, wherein it was explicitly
guaranteed that goods imported from the Dominican Republic would not be subjected to higher tariffs
compared to imports from any other nation.
The crux of Whitney's claim hinged on the perceived violation of the treaty's principle of equal tariff
treatment between the United States and the Dominican Republic. However, a crucial counterpoint
existed in the form of a Congressional act that authorized the collection of duties on goods coming from
the Dominican Republic. Notably, this statute was enacted subsequent to the treaty's establishment
between the two countries. In the initial trial, the lower court ruled in favor of Robertson, asserting the
legality of the duties imposed on Whitney's sugar imports. Unsatisfied with the outcome, Whitney
pursued an appeal to seek a different verdict on the matter.
Issue
Whether or not a conflict arises between a treaty and a legislative act, the determining factor rests on the
sequence of their enactment, favoring the supremacy of the more recent one.
Ruling
Yes. In the context of a conflict arising between a treaty and a legislative act, precedence is accorded to
the document with the more recent date of enactment. This principle finds validation in the present case
where the act of Congress, which facilitated the imposition of duties on the imported sugar, came into
existence subsequent to the treaty in question. As a result, the hierarchy of authority tilts in favor of the
more recently promulgated statute, thereby solidifying its supremacy over the earlier treaty. This verdict
stands as a validation of the sequence of enactment as a decisive criterion in resolving such discrepancies.
It is imperative to emphasize that the coexistence of a later inconsistent statute alongside a pre-existing
treaty does not inherently nullify or revoke the treaty itself. While the specific terms of the treaty might
not retain their enforceability in the face of a subsequent contradictory legislative act, the treaty's status as
a binding international commitment persists. This ruling reinforces the enduring legal relevance of the
treaty, albeit in a constrained capacity, within the legal framework. This distinction underscores the
nuanced interplay between domestic legislation and international obligations, illustrating that while
legislative acts might alter the practical applicability of certain treaty clauses, the treaty's fundamental
legal standing remains intact.

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