Hughes v. Oklahoma

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Hughes v. Oklahoma
Seal of the United States Supreme Court.svg
Argued January 9, 1979
Decided April 24, 1979
Full case name William Hughes v. Oklahoma
Citations 441 U.S. 322 (more)
99 S.Ct. 1727; 60 L.Ed.2d 250
Prior history Appeal from the Court of Criminal Appeals of Oklahoma
Holding
The Congress may enact legislation governing wildlife on federal lands. When conflicting state law exists, the supremacy clause ensures that federal legislation will prevail.
Court membership
Case opinions
Majority Brennan, joined by Stewart, White, Marshall, Blackmun, Powell, Stevens
Dissent Rehnquist, joined by Burger

Hughes v. Oklahoma, 441 U.S. 322 (1979), was a United States Supreme Court decision, which held that the United States Congress may enact legislation governing wildlife on federal lands. When conflicting state law exists, the supremacy clause ensures that federal legislation will prevail. The Court thereby overruled Geer v. Connecticut (1896), rejecting the earlier case's "19th century legal fiction of state ownership" of wildlife. In the Court’s view, this "fiction" had "been eroded to the point of virtual extinction in cases involving regulation of wild animals." With the fall of Geer, the last precedential impediment to the federal government's wildlife management authority was removed. The case stemmed from Hughes being convicted of shipping minnows fished from Oklahoma waters out of the state.

The Dormant Commerce Clause Doctrine

Oklahoma enacted statutes that prevented any person from selling minnows found within the natural waters of the state of Oklahoma outside of the state of Oklahoma. Oklahoma claimed that the purpose of the statute was for wildlife conservation. The Supreme Court held that the statute violated the Dormant Commerce Clause because it discriminated the flow of interstate commerce without being the least discriminatory alternative.

See also[edit]

Further reading[edit]

  • Axline, M. D. (1981). "The End of a Wildlife Era: Hughes v. Oklahoma". Oregon Law Review 60: 413. 
  • Hellerstein, Walter (1979). "Hughes v. Oklahoma: The Court, the Commerce Clause, and State Control of Natural Resources". The Supreme Court Review 1979: 51–93. JSTOR 3109566. 
  • Matthews, Olen Paul (1986). "Who Owns Wildlife?". Wildlife Society Bulletin 14 (4): 459–465. JSTOR 3782288.