Edwards v. California
Encyclopedia
Edwards v. People of State of California, was a United States Supreme Court
case where a California
law prohibiting the bringing of a non-resident "indigent person" into the state was struck down as unconstitutional
.
The so-called, "anti-Okie" law made it a misdemeanor to bring into California "any indigent person who is not a resident of the State, knowing him to be an indigent person". Edwards was a Californian who had driven to Texas and returned with his unemployed brother-in-law. He was tried, convicted and given a six-month suspended sentence. On appeal from the Superior Court of Yuba County
, the Supreme Court unanimously vacated the verdict and declared the law unconstitutional, as violating the Constitution's
Commerce Clause
. Justice Byrnes wrote the majority opinion. In concurring opinions, Justices Douglas
joined by Justices Black
and Murphy
, and Justice Jackson
held that the law violated the Privileges or Immunities clause
of the Fourteenth Amendment
.
In further support of its decision, the Court discusses the fact that no state may isolate itself from the troubles of the Union, as it defies the political philosophy under which the Constitution was framed. As a social issue common to all states, indigence must be addressed on a national level, and no single state may address such problems by simply “closing its gates” in an effort to ignore the problem, as evidenced in the case of Baldwin v. Seelig. Such programs as Social Security and public works employment are submitted as evidence that the United States, both on a state and federal level, acknowledges that poverty and unemployment must be dealt with cooperatively at all levels of government. As such, the section in question squarely conflicts with the goals of the Constitution. (Attention is also given to the issue of the state’s authority to regulate the transport of “paupers,” to which the court responds that the historical context of the word is in no way applicable to Mr. Duncan and therefore holds no ground in the matter.) Chief Justice Byrnes concludes the Court’s opinion by stating that it is unnecessary to further attack California’s actions on the basis of additional Constitutional infractions.
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
case where a California
California
California is a state located on the West Coast of the United States. It is by far the most populous U.S. state, and the third-largest by land area...
law prohibiting the bringing of a non-resident "indigent person" into the state was struck down as unconstitutional
Constitutionality
Constitutionality is the condition of acting in accordance with an applicable constitution. Acts that are not in accordance with the rules laid down in the constitution are deemed to be ultra vires.-See also:*ultra vires*Company law*Constitutional law...
.
The so-called, "anti-Okie" law made it a misdemeanor to bring into California "any indigent person who is not a resident of the State, knowing him to be an indigent person". Edwards was a Californian who had driven to Texas and returned with his unemployed brother-in-law. He was tried, convicted and given a six-month suspended sentence. On appeal from the Superior Court of Yuba County
Yuba County, California
Yuba County is a county located in the U.S. state of California's Central Valley, north of Sacramento, along the Feather River. As of the 2010 census, its population was 72,155. The county seat is Marysville. Yuba County is part of the Greater Sacramento area.-History:Yuba County was one of the...
, the Supreme Court unanimously vacated the verdict and declared the law unconstitutional, as violating the Constitution's
United States Constitution
The Constitution of the United States is the supreme law of the United States of America. It is the framework for the organization of the United States government and for the relationship of the federal government with the states, citizens, and all people within the United States.The first three...
Commerce Clause
Commerce Clause
The Commerce Clause is an enumerated power listed in the United States Constitution . The clause states that the United States Congress shall have power "To regulate Commerce with foreign Nations, and among the several States, and with the Indian Tribes." Courts and commentators have tended to...
. Justice Byrnes wrote the majority opinion. In concurring opinions, Justices Douglas
William O. Douglas
William Orville Douglas was an Associate Justice of the United States Supreme Court. With a term lasting 36 years and 209 days, he is the longest-serving justice in the history of the Supreme Court...
joined by Justices Black
Hugo Black
Hugo Lafayette Black was an American politician and jurist. A member of the Democratic Party, Black represented Alabama in the United States Senate from 1927 to 1937, and served as an Associate Justice of the Supreme Court of the United States from 1937 to 1971. Black was nominated to the Supreme...
and Murphy
Frank Murphy
William Francis Murphy was a politician and jurist from Michigan. He served as First Assistant U.S. District Attorney, Eastern Michigan District , Recorder's Court Judge, Detroit . Mayor of Detroit , the last Governor-General of the Philippines , U.S...
, and Justice Jackson
Robert H. Jackson
Robert Houghwout Jackson was United States Attorney General and an Associate Justice of the United States Supreme Court . He was also the chief United States prosecutor at the Nuremberg Trials...
held that the law violated the Privileges or Immunities clause
Privileges or Immunities Clause
The Privileges or Immunities Clause is Amendment XIV, Section 1, Clause 2 of the United States Constitution. It states:Along with the rest of the Fourteenth Amendment, this clause became part of the Constitution on July 9, 1868....
of the Fourteenth Amendment
Fourteenth Amendment to the United States Constitution
The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments.Its Citizenship Clause provides a broad definition of citizenship that overruled the Dred Scott v...
.
Factual background
Edwards was a citizen of the United States and a Californian resident who, in December 1939, left his home in the city of Marysville for Spur, Texas, with the intent of picking up his brother-in-law, Frank Duncan, (a US citizen and resident of Texas) and returning home to California with the man. During the course of his trip, Edwards was made aware of the fact that Duncan was unemployed, having little money and few personal possessions. As such, Duncan was classified as an indigent individual under California state law, the transportation of which into the state was strictly prohibited. Section 2615 of the Welfare and Institutions Code of California declares, “Every person, firm or corporation, or officer or agent thereof that brings or assists in bringing into the State any indigent person who is not a resident of the State, knowing him to be an indigent person, is guilty of a misdemeanor.” A complaint was subsequently filed against Edwards in Justice Court, where he was convicted and sentenced to six months imprisonment in the county jail. Edwards appealed to the Superior Court of Yuba County, and later to the Supreme Court of the United States on the argument that his sentence was unconstitutional on the basis that the California law violated the Interstate Commerce Clause.Holding
The Court found that Section 2615 of the Welfare and Institutions Code of California violated Article 1, Section 8 of the Constitution.Majority opinion
Chief Justice Byrnes delivered the opinion of the Supreme Court, in which he opens with a discussion of Article 1, Section 8. Byrnes notes that the Interstate Commerce Clause grants Congress the expressed right and duty to the regulation of commercial activities between states, and that the provision states beyond doubt that the transportation of people across state boundaries qualifies as commerce. Therefore, any state law aimed toward prohibiting the transport of an individual is, by the opinion of the court, “an unconstitutional barrier to interstate commerce.” In the defense of Section 2615, California noted that recent influxes of migrant laborers into the state had generated complex issues throughout the local economy, contributing to downturns in healthcare and morality among the general population. The legislature was therefore aimed at stopping the influx of individuals who were, by the accusations of the state, imposing a drain upon society. Chiefly, this moral proposition served as the backbone of California’s argument. However, the Supreme Court noted that in the case of Olsen v. Nebraska, it had been established that it was not the duty of the justices to pass judgment upon “the wisdom, need, or appropriateness” of the legislative efforts of the states, but rather to judge the constitutionality of such legislature.In further support of its decision, the Court discusses the fact that no state may isolate itself from the troubles of the Union, as it defies the political philosophy under which the Constitution was framed. As a social issue common to all states, indigence must be addressed on a national level, and no single state may address such problems by simply “closing its gates” in an effort to ignore the problem, as evidenced in the case of Baldwin v. Seelig. Such programs as Social Security and public works employment are submitted as evidence that the United States, both on a state and federal level, acknowledges that poverty and unemployment must be dealt with cooperatively at all levels of government. As such, the section in question squarely conflicts with the goals of the Constitution. (Attention is also given to the issue of the state’s authority to regulate the transport of “paupers,” to which the court responds that the historical context of the word is in no way applicable to Mr. Duncan and therefore holds no ground in the matter.) Chief Justice Byrnes concludes the Court’s opinion by stating that it is unnecessary to further attack California’s actions on the basis of additional Constitutional infractions.