Missouri v. Holland

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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]
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.
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Dissent
Justices Willis Van Devanter and Mahlon Pitney dissented but did not issue opinions.
See also
- Nondelegation doctrine
- Separation of powers
- The Taft Court
- Supreme Court of the United States
- History of the Supreme Court
External links
- Full text of case syllabus and opinions (Justia)
- Supreme Court of the United States
- Search Google News for this topic
Footnotes
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