[Footnote 3: _United States v. Doremus_, 249 U.S., 86, decided in 1919.]

[Footnote 4: 38 Stat., 785.]

[Footnote 5: _Smith v. Kansas City Title Company_, 255 U.S., 180, 210.]


In the Narcotic Drug Act case[1] the Court held

While Congress may not exert authority which is wholly
reserved to the states, the power conferred by the
Constitution to levy excise taxes, uniform throughout the
United States, is to be exercised at the discretion of
Congress; and, where the provisions of the law enacted have
some reasonable relation to this power, the fact that they may
have been impelled by a motive, or may accomplish a purpose,
other than the raising of revenue, cannot invalidate them; nor
can the fact that they affect the conduct of a business which
is subject to regulation by the state police power.

[Footnote 1: _United States v. Doremus_, 249 U.S., 86.]

It is true that, while the Supreme Court may not question congressional
motives, it cannot escape the obligation to construe a statute in the
light of its true nature and effect. The Court has said:[1]

The direct and necessary result of a statute must be taken
into consideration when deciding as to its validity, even if
that result is not in so many words either enacted or
distinctly provided for. In whatever language a statute may be