Edwards v. California
Edwards v. California is a landmark Supreme Court case from the Great Depression era that addressed the constitutionality of California's "Okie Law," which sought to prohibit the entry of indigent individuals into the state. The Court unanimously ruled that this law was unconstitutional, emphasizing the importance of the right to travel across state lines. The majority opinion, delivered by Justice James F. Byrnes, interpreted the issue through the lens of the commerce clause in the Constitution, likening the movement of people to interstate commerce. Justice Robert H. Jackson, while agreeing with the Court's conclusion, critiqued the reasoning that equated humans with property, advocating instead for the use of the Fourteenth Amendment's privileges and immunities clause to affirm citizens' right to travel.
This case highlights the complex interactions between state laws and federal constitutional rights, particularly regarding the treatment of individuals during times of economic hardship. It underscores the evolving interpretation of civil rights in American jurisprudence, especially in relation to mobility and economic conditions. The ruling has implications for understanding how state regulations can impact constitutional freedoms and serves as a significant reference point in discussions about the rights of marginalized populations.
Edwards v. California
Date: November 24, 1941
Citation: 314 U.S. 160
Issue: Right to travel
Significance: The Supreme Court, in striking down a law barring indigents from entering California, strengthened the constitutional right to travel, especially for poor citizens.
The Supreme Court unanimously ruled that California’s Great Depression era “Okie Law” was unconstitutional in its attempt to bar any person from bringing an indigent person into California. Justice James F. Byrnes, in his opinion for the Court, relied on Article I, section 8 of the Constitution (the commerce clause) and viewed the issue as the transportation of people as if they were property in interstate commerce. In his concurrence, Justice Robert H. Jackson agreed with the result but attacked the reasoning. He objected to equating people with property to give them constitutional rights as U.S. citizens. Jackson argued that the Fourteenth Amendment’s privileges and immunities clause should be used to grant people the right to travel across state lines, which he saw as a basic feature of U.S. citizenship. Jackson’s view would strengthen the privileges and immunities clause, which is not frequently cited by the Court.
