Coyle v. Smith
221 U.S. 559 (1911)
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Rule of Law:
Under the 'equal footing doctrine,' Congress cannot impose conditions upon the admission of a new state that would diminish its sovereign powers and place it on an unequal footing with the original states. The power to locate a state's seat of government is a core attribute of state sovereignty that cannot be restricted by Congress as a condition of admission.
Facts:
- In the Enabling Act of June 16, 1906, the U.S. Congress set the terms for Oklahoma's admission to the Union.
- Section 2 of the Act mandated that the temporary state capital be located at Guthrie.
- The Act further stipulated that the capital could not be moved from Guthrie before the year 1913.
- The Act required that any relocation after 1913 be determined by a vote of the state's electors.
- Oklahoma's constitutional convention accepted the terms of the Enabling Act via an 'ordinance irrevocable.'
- On December 29, 1910, the Oklahoma Legislature passed an act to immediately move the state capital from Guthrie to Oklahoma City.
- This 1910 state law also appropriated public funds for the construction of new capital buildings in Oklahoma City.
- Coyle, along with other taxpayers and property owners in Guthrie, asserted their interests would be negatively affected by the capital's relocation.
Procedural Posture:
- Coyle and other Guthrie taxpayers filed a proceeding directly in the Supreme Court of Oklahoma, which had been granted original jurisdiction for such matters.
- The plaintiffs challenged the constitutionality of the Oklahoma act of December 29, 1910, arguing it violated the terms of the federal Enabling Act of 1906.
- The Supreme Court of Oklahoma upheld the state's removal act, ruling against the plaintiffs.
- The plaintiffs (now plaintiffs in error) sought and were granted a writ of error from the U.S. Supreme Court to review the judgment of the Supreme Court of Oklahoma.
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Issue:
Does a condition in a congressional enabling act that restricts a new state's power to locate its own capital remain binding and enforceable against the state after its admission to the Union?
Opinions:
Majority - Mr. Justice Lurton
No. A condition in an enabling act that restricts a new state's power to locate its capital is not binding after admission because it violates the constitutional principle of equal footing among the states. The power to locate its own seat of government is an essential and peculiar state power, inherent in its sovereignty. The Union is one of equal states, and Congress's power to admit new states does not include the power to admit a state with lesser powers than the original members. While Congress may impose conditions related to matters within its constitutional authority (such as federal lands or commerce), it cannot impose conditions that permanently impair a state's core sovereign functions over its internal affairs. Once admitted, Oklahoma possesses the same rights of dominion and sovereignty as the original states, including the unencumbered power to decide the location of its capital.
Dissenting - Mr. Justice McKenna and Mr. Justice Holmes
The opinion notes that Mr. Justice McKenna and Mr. Justice Holmes dissented but does not include a written dissenting opinion.
Analysis:
This case firmly establishes the modern 'equal footing doctrine,' which ensures that all states, new and old, are co-equal sovereigns within the Union. The ruling clarifies the limits of Congress's power under the Admissions Clause, distinguishing between permissible conditions that fall under federal jurisdiction (e.g., public lands) and impermissible conditions that infringe upon the fundamental attributes of state sovereignty. Coyle v. Smith prevents Congress from creating a class of 'junior' states with diminished powers, thereby reinforcing the constitutional structure of federalism and the principle that a state's internal governance is beyond federal control.
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