Missouri v. Holland

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Supreme Court of the United States
Missouri v. Holland
Reference: 252 U.S. 416
Term: 1920
Important Dates
Argued: March 2, 1920
Decided: April 19, 1920
Outcome
United States District Court for the Western District of Missouri affirmed
Majority
Chief Justice Edward White • Joseph McKenna • Oliver Holmes • William R. Day • James C. McReynolds • Louis Brandeis • John Clarke
Dissenting
Willis Van Devanter • Mahlon Pitney

Missouri v. Holland is a case decided on April 19, 1920, by the United States Supreme Court that determined federal laws established to implement valid U.S. treaties were supreme over state laws or preferences. The case concerned the Migratory Bird Treaty Act of 1918 and whether the federal government could pass laws governing the killing, trapping, and selling of game (powers not expressly delegated to the federal government) to implement the terms of a treaty entered into with another country. The Supreme Court affirmed the ruling of the United States District Court for the Western District of Missouri, holding that the law was a constitutional exercise of the U.S. government's treaty power.[1]

HIGHLIGHTS
  • The case: The state of Missouri filed a lawsuit to prevent U.S. Game Warden Ray Holland from enforcing the Migratory Bird Treaty Act of 1918, claiming the law exceeded the federal government's enumerated powers under the Tenth Amendment and that the right to regulate the killing, trapping, and selling of game belonged to states.
  • The issue: Can states challenge U.S. treaties on Tenth Amendment grounds?
  • The outcome: The Supreme Court held that states could not challenge valid treaties on Tenth Amendment grounds alone because the treaty power was expressly delegated to the U.S. government.


    • Why it matters: The Supreme Court determined that federal laws established to implement valid U.S. treaties were supreme over state laws or preferences. Writing for the court, Justice Oliver Holmes argued that the federal government had a legitimate interest in passing the Migratory Bird Treaty Act of 1918 and that the treaty power was enumerated and not subject to further restrictions under the Tenth Amendment.

    Background

    The United States entered into a valid treaty with Great Britain on August 16, 1916, which bound the United States and Canada to implement legislation to protect certain migratory game bird species such as geese and ducks. Congress passed the Migratory Bird Treaty Act of 1918, restricting the killing, trapping, and selling of game birds as specified in the treaty.[1]

    Missouri filed suit to prevent U.S. Game Warden Ray Holland from enforcing the Migratory Bird Treaty Act of 1918. The state claimed the law exceeded the federal government's enumerated powers under the Tenth Amendment and that the right to regulate the killing, trapping, and selling of game belonged to states.[1]

    The United States District Court for the Western District of Missouri decided the law was a constitutional exercise of the U.S. government's treaty power, and Missouri appealed the case to the Supreme Court.[1]

    Oral argument

    Oral argument was held on March 2, 1920. The case was decided on April 19, 1920.[1]

    Decision

    The Supreme Court decided 7-2 that the Migratory Bird Treaty Act of 1918 was constitutional under the federal government's Article 2, Section 2, treaty power and the Supremacy Clause.[1]

    Opinions

    Opinion of the court

    Justice Oliver Holmes, writing for the court, argued that the federal government had a legitimate interest in passing the Migratory Bird Treaty Act of 1918 and that the treaty power was enumerated and not subject to further restrictions under the Tenth Amendment.

    “ To answer this question, it is not enough to refer to the Tenth Amendment, reserving the powers not delegated to the United States, because, by Article II, § 2, the power to make treaties is delegated expressly, and by Article VI treaties made under the authority of the United States, along with the Constitution and laws of the United States made in pursuance thereof, are declared the supreme law of the land. If the treaty is valid, there can be no dispute about the validity of the statute under Article I, § 8, as a necessary and proper means to execute the powers of the Government. The language of the Constitution as to the supremacy of treaties being general, the question before us is narrowed to an inquiry into the ground upon which the present supposed exception is placed.


    Here, a national interest of very nearly the first magnitude is involved. It can be protected only by national action in concert with that of another power. The subject matter is only transitorily within the State, and has no permanent habitat therein. But for the treaty and the statute, there soon might be no birds for any powers to deal with. We see nothing in the Constitution that compels the Government to sit by while a food supply is cut off and the protectors of our forests and our crops are destroyed. It is not sufficient to rely upon the States. The reliance is vain, and were it otherwise, the question is whether the United States is forbidden to act.[1][2]

    		”

    Dissent

    Justices Willis Van Devanter and Mahlon Pitney dissented but did not issue opinions.

    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 1.5 1.6 Justia, "Missouri v. Holland, 252 U.S. 416 (1920)," accessed June 9, 2022
    2. ↑ Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
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