1941 United States Supreme Court case
Edwards v. California Argued April 28–29, 1941 Full case name Edwards v. People of State of California Citations 314U.S. 160 (more Case history Prior Probable jurisdiction noted, 61 S. Ct. 395 (1941); reargument ordered,313 U.S. 545 (1941). Holding A state cannot prohibit indigent people from moving into it. Court membership Chief Justice Harlan F. Stone Associate Justices Owen Roberts · Hugo Black Stanley F. Reed · Felix Frankfurter William O. Douglas · Frank Murphy James F. Byrnes · Robert H. Jackson Case opinions Majority Byrnes, joined by Stone, Roberts, Reed, Frankfurter Concurrence Douglas, joined by Black, Murphy Concurrence Jackson
Edwards v. People of State of California landmark [ 1] [ 2] United States Supreme Court case where aCalifornia law prohibiting the bringing of a non-resident "indigent person" into the state was struck down asunconstitutional .
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 ofYuba County , the Supreme Court unanimously vacated the verdict and declared the law unconstitutional, as violating theConstitution's Commerce Clause .Justice Byrnes wrote the majority opinion. In concurring opinions, JusticesDouglas joined by JusticesBlack andMurphy , and JusticeJackson held that the law violated thePrivileges or Immunities clause of theFourteenth Amendment .[ 3]
Edwards was a citizen of the United States and a Californian resident. In December 1939, he left his home inMarysville forSpur, Texas , with the intent of picking up his brother-in-law, Frank Duncan, a citizen of the US and ofTexas , and returning home to California with Duncan. During the course of his trip, Edwards was made aware of the fact that Duncan was unemployed and had 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 under Section 2615 of the Welfare and Institutions Code of California: "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 Commerce Clause.
The Court found that Section 2615 of the Welfare and Institutions Code of California violated Article 1, Section 8 of the Constitution.
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.[ 3]
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