Edwards v. California
|Edwards v. California|
|Argued April 28–29, 1941
Reargued October 21, 1941
Decided November 24, 1941
|Full case name||Edwards v. People of State of California|
|Citations||314 U.S. 160 (more)|
|A state cannot prohibit indigent people from moving into it.|
|Majority||Byrnes, joined by Stone, Roberts, Reed, Frankfurter|
|Concurrence||Douglas, joined by Black, Murphy|
Edwards v. People of State of California, 314 U.S. 160 (1941), 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.
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.
The Court found that Section 2615 of the Welfare and Institutions Code of California violated Article 1, Section 8 of the Constitution.
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.
It is worth noting that in writing their concurring opinions, the additional justices chose to forgo the explanation that California had violated Article 1, Section 8 of the Constitution, arguing that defining the transportation of human beings as “commerce” raises a number of troubling moral questions which undermine individual rights and devalue the original intent of the Commerce Clause. Instead, they propose the idea that the impairment of one’s ability to freely traverse interstate borders is a violation of the implied rights of US citizenship, and thereby violates the 14th Amendment and the individual’s right to equal protection.
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