of 1926 as an attempt to punish a state violation through taxation. The Court ruled that the primary purpose of the tax law was to enforce federal police powers, and not to raise revenue. After repeal of the Eighteenth Amendment, the federal law was no longer enforceable. The Supreme Court's opinion in National Federation of Independent Business v. Sebelius (2012) referenced the logic of Constantine in determining whether the Affordable Care Act was a penalty or a tax in terms of the Constitution; the Court held it was a tax, after "[d]isregarding the designation of the exaction, and viewing its substance and application". Federal court system Under the Judiciary Act of 1789 the federal court structure at the time comprised District Courts, which had general trial jurisdiction; Circuit Courts, which had mixed trial and appellate (from the US District Courts) jurisdiction; and the United States Supreme Court, which had appellate jurisdiction over the federal District and Circuit courts—and for certain issues over state courts. The Supreme Court also had limited original jurisdiction (i.e., in which cases could be filed directly with the Supreme Court without first having been heard by a lower federal or state court). There were one or more federal District Courts and/or Circuit Courts in each state, territory, or other geographical region. The Judiciary Act of 1891 created the United States Courts of Appeals and reassigned the jurisdiction of most routine appeals from the district and circuit courts to these appellate courts. The Act created nine new courts that were originally known as the "United States Circuit Courts of Appeals." The new courts had jurisdiction over most appeals of lower court decisions. The Supreme Court could review either legal issues that a court of appeals certified or decisions of court of appeals by writ of certiorari. On January 1, 1912, the effective date of the Judicial Code of 1911, the old Circuit Courts were abolished, with their remaining trial court jurisdiction transferred to the U.S. District Courts. List of cases in volume 296 U.S. [a] Hughes took no part in the case [b] McReynolds took no part in the case [c] Stone took no part in the case Notes and references External links Case reports in volume 296 from Library of Congress Case reports in volume 296 from Court Listener Case reports in volume 296 from the Caselaw Access Project of Harvard Law School Case reports in