Missouri v. Holland
"Missouri v. Holland" is a significant Supreme Court case decided in 1920, which addressed the balance of power between state and federal authority concerning wildlife conservation. The case arose when the state of Missouri sought to block the enforcement of regulations under the Migratory Bird Treaty Act of 1918, arguing that such federal laws encroached upon state rights as outlined in the Tenth Amendment. The Supreme Court, in a 7-2 decision, upheld the federal law, asserting that the government has the authority to implement treaties that are recognized as the supreme law of the land under the supremacy clause of the Constitution. Justice Oliver Wendell Holmes Jr. wrote the opinion for the Court, emphasizing the necessity for federal power in enforcing international agreements. This ruling was contentious at the time, reflecting broader debates about states' rights versus federal oversight. Over the decades, the significance of the case has diminished as federal authority in various domestic matters has expanded. The dissenting opinion, voiced by Justices Van Devanter and Pitney, highlighted a traditional conservative perspective favoring states’ rights. "Missouri v. Holland" remains a pivotal reference point in discussions concerning environmental law and the relationship between state and federal governance.
Missouri v. Holland
Date: April 19, 1920
Citation: 252 U.S. 416
Issue: Treaties
Significance: The Supreme Court created a new federal power to act in accordance with treaties.
The state of Missouri tried to prevent the enforcement of a statute resulting from the Migratory Bird Treaty Act of 1918, charging that the law intruded on the rights reserved to the states under the Tenth Amendment. By a 7-2 vote, the Supreme Court upheld the federal law enacted in compliance with the migratory bird treaty. An earlier decision not involving a treaty had held that states owned the birds within their borders, but in his opinion for the Court, Justice Oliver Wendell Holmes found that the federal government had to have the power to comply with treaties that, under the supremacy clause of Article VI, were the supreme law of the land. Controversial at the time, this decision lost its significance beginning in the 1930’s as federal power in the domestic area was greatly expanded. Justices Willis Van Devanter and Mahlon Pitney alone among the conservatives dissented, upholding the traditional states’ rights viewpoint.
