The Court handed down its decision on April 8, 1895, with Chief Justice Melville Fuller delivering the opinion of the Court. He ruled in Pollock's favor, stating that the taxes levied by the Wilson-Gorman Act on income from property were unconstitutional. The Court treated the tax on income from property as a direct tax. The Constitution of the United States then said that such direct taxes were required to be imposed in proportion to the states' population. The tax in question had not been apportioned and so was invalid. As Chief Justice Fuller stated: