Hylton v. United States (1796), 3 U.S. 171, 173, 3 Dall. 171, the Supreme Court upheld an unapportioned tax on carriages. The Court recognize that there may be indirect taxes that are not excise taxes. Justice Chase stated: If there are any other species of taxes that are not direct, and not included within the words duties, imposts, or excises, they may be laid by the rule of uniformity or not, as congress shall think proper and reasonable. If the framers of the constitution did not contemplate other taxes than direct taxes, and duties, imposts and excises, there is a great inaccuracy in their language. If these four species of taxes were all that were meditated, the general power to lay taxes was unnecessary. (Id. at 173, 3 U.S. 171. The statute at issue in Hylton, Act of June 5, 1794, ch. 45, 1 Stat. 373 (repealed 1796), imposed a tax "upon all carriages for the conveyance of persons, which shall be kept by or for any person, for his or her own use, or to be let out to hire, or for the conveying of passengers." Id. at 373-74. The Court rejected the plaintiff's challenge to the carriage tax as an unapportioned direct tax, holding that the carriage tax was indirect. Hylton, however, was not entirely clear as to the standard to be used in distinguishing direct taxes from indirect taxes. Three Justices participated in the decision, each writing a separate opinion. Justice Chase declined to "give a judicial opinion" as to what was encompassed in the category of direct taxes, but he expressed his inclination "that the direct taxes contemplated by the constitution, are only two, to wit, a capitation or poll tax . . . and a tax on land." 3 U.S. (3 Dall.) at 175. Justice Chase further explained that a tax on "a consumable commodity . . . is on the expense of the owner," and therefore should be considered an indirect tax. Id. Justice Paterson also declined to decide "whether direct taxes, in the sense of the constitution, comprehend any other tax than a capitation tax, and a tax on land," id. at 177, but he affirmatively stated that "all taxes on expenses or consumption are indirect taxes," id. at 180. Justice Iredell noted that "perhaps a direct tax, in the sense of the constitution, can mean nothing but a tax on something inseparably annexed to the soil, something capable of apportionment under all such circumstances. A land or a poll tax may be considered of this description. . . . In regard to other articles, there may possibly be considerable doubt." Id. at 183. Declining to decide the precise parameters of a direct tax, Justice Iredell concluded that "it is sufficient, on the present occasion, for the court to be satisfied that this is not a direct tax," id. at 183, because it would have been "manifestly absurd" to apportion the carriage tax, id. at 182. Each of the three Justices that wrote an individual opinion, Justice Chase, Justice Paterson, and Justice Iredell, concluded that a rule of apportionment with respect to the carriage tax would be impractical and "create great inequality and injustice" because the number of carriages in a state did not necessarily correlate to the state's population. Id. at 174; see also id. at 179; id. at 183. Though Justice Wilson, writing separately, stated that he found it unnecessary to participate in the decision, he agreed that the tax was constitutional without providing his reasons. Id. at 183-84.