408 HARVARD LAW REVIEW. CongresL had passed to raise a revenue from duties on imports and tonnage." ^ It was contended by the importers that as Congress had not yet made San Francisco a port of entry or constituted any collection district in California the tariff law could not apply. To this the court replied as follows: "Can any reason be given for the exemption of foreign goods from duty because they have not been entered and collected at a port of delivery ? The last became a part of the consumption of the country, as well as the others. They may be carried from the point of landing into collection districts within which duties have been paid upon the same kinds of goods; thus entering, by the retail sale of them, into competition with such goods, and with our own manufactures, and the products of our own farmers and planters. The right claimed to land foreign goods within the United States at any place out of a collection district, if allowed, would be a violation of that provision in the Constitution which . enjoins that all duties, imposts, and excises, shall be uniform throughout the United States. Indeed, it piust be very clear that no such right exists, and that there was nothing in the condition of California to exempt importers of foreign goods into it from the payment of the same duties which were chargeable in the other ports of the United States. As to the denial of the authority of the President to prevent the landing of foreign goods in the United States out of a collection district, it can only be necessary to say, if he did not do so, it would be a neglect of his constitutional obligation 'to take care that the laws be carefully executed.' " ^ Many other difficulties of a constitutional character must be en- countered, and more than can be noticed in the limits appropriate for an article like this. I will note two which address themselves particularly to the consideration of the political departments of our government. I. The XIV. Amendment declares that should any State abridge or deny the right of suffrage as to any of its adult male inhabitants who are citizens of the United States, except for crime, its repre- sentation in Congress shall be correspondingly reduced. This applies in terms only to the States; but does it not state a constitutional principle — that of manhood suffrage for every citizen — which the spirit of this Amendment requires us to observe in deahng with our Territories? Such would seem to have been its legislative construction in the Title of the Revised ^ Cross V. Harrison, i6 Howard, 197. " Cross v. Harrison, 16 Howard, 198.
