Coyle v. Smith
Coyle v. Smith is a significant Supreme Court case that addressed the authority of Congress in imposing conditions on states after their admission to the Union. The case arose when Oklahoma, which had accepted the stipulation of Guthrie as its capital upon statehood in 1907, sought to relocate its capital to Oklahoma City after three years. Citizens opposed to this move challenged the legality of Congressional conditions, questioning whether such restrictions could remain enforceable post-admission. In a 7-2 ruling, the Supreme Court held that Congress's imposition of conditions that hindered state equality was unconstitutional, thereby affirming Oklahoma's right to designate its own capital. The majority opinion, written by Justice Horace H. Lurton, emphasized that while the Constitution does not explicitly address this scenario, the principle of state equality is a vital, albeit unwritten, tradition. This case highlights the balance of power between federal authority and state sovereignty, illustrating an essential aspect of the relationship between the states and the federal government in the context of American governance.
Coyle v. Smith
Date: May 29, 1911
Citation: 221 U.S. 559
Issue: Territories and new states
Significance: The Supreme Court, citing the equality of states, ruled that Congress could not impose conditions on a territory that remained valid after it had become a state.
When Congress passed legislation admitting Oklahoma as a state, it stipulated that Guthrie was to be the capital until 1913. Oklahoma accepted this provision when it became a state in 1907, but after three years, it decided to move the capital to Oklahoma City. Some citizens asked the Supreme Court to decide if Congress could impose conditions that remained valid after admission. After examining cases relating back to the Northwest Ordinance of 1787, the Court, by a vote of 7-2, found that congressional restrictions were an impermissible infringement that made Oklahoma unequal with other states. Justice Horace H. Lurton, writing for the majority, stated that although the Constitution did not explicitly deal with this issue, the Court viewed state equality as an unwritten tradition.