Hines, Secretary of Labor & Industry of Pennsylvania v. Davidowitz
(1941)
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Rule of Law:
Under the Supremacy Clause, a state law is preempted and rendered unenforceable if it stands as an obstacle to the accomplishment and execution of the full purposes and objectives of a comprehensive federal statutory scheme, particularly in a field of paramount federal interest such as immigration and foreign affairs.
Facts:
- In 1939, the Commonwealth of Pennsylvania enacted an Alien Registration Act.
- The Pennsylvania Act required every alien 18 years or older to register annually with the state.
- Registrants were required to pay a $1 annual fee and provide detailed personal information.
- The Act mandated that registered aliens receive an identification card which they must carry at all times.
- Aliens were required to show this card upon demand to any police officer or agent of the state's Department of Labor and Industry.
- Failure to register or carry the card was punishable by fines or imprisonment.
- In 1940, the United States Congress enacted a federal Alien Registration Act.
- The federal Act required a single, one-time registration of aliens aged 14 and over, required fingerprinting, and mandated the secrecy of registration files, but did not require aliens to carry an identification card.
Procedural Posture:
- Davidowitz, an alien, sued Hines and other Pennsylvania officials in the U.S. District Court for the Eastern District of Pennsylvania.
- The lawsuit sought an injunction to prevent the enforcement of the Pennsylvania Alien Registration Act.
- A three-judge District Court was convened to hear the case.
- The District Court granted the injunction, holding that the Pennsylvania Act was unconstitutional.
- Hines and the other state officials, as appellants, appealed the District Court's judgment directly to the U.S. Supreme Court.
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Issue:
Does the federal Alien Registration Act of 1940, which establishes a comprehensive and uniform system for the registration of aliens, preclude the enforcement of Pennsylvania's Alien Registration Act of 1939?
Opinions:
Majority - Justice Black
Yes, the federal Alien Registration Act of 1940 precludes the enforcement of Pennsylvania's law. The regulation of aliens is a matter of national concern so intimately blended with foreign relations that it requires a uniform federal rule. The federal government possesses superior authority in this field, and when it enacts a complete and comprehensive scheme of regulation, state laws that conflict with, interfere with, curtail, or complement the federal law must yield. The test is whether the state law stands as an obstacle to the accomplishment of Congress's full objectives. Here, Congress established a single, integrated, and all-embracing system for alien registration, deliberately omitting burdensome requirements like annual registration and the carrying of an identification card to protect aliens' personal liberties and avoid generating disloyalty. Pennsylvania's law, with its additional and more stringent requirements, creates such an obstacle and interferes with the uniform national system established by Congress.
Dissenting - Justice Stone
No, the federal act does not preclude enforcement of the Pennsylvania law. A state law should not be struck down by 'vague inferences' about congressional intent; it must plainly and palpably conflict with federal law. States retain their police powers to legislate on matters concerning the social order and safety of their people, including laws applicable to aliens, so long as they are rational. There is no direct conflict here, as an alien could comply with both statutes. The federal act contains no language expressing an intent to occupy the field exclusively or to repeal existing state laws. In a system of dual sovereignty, a federal registration act to prevent subversive activities can consistently stand with a state registration act passed in aid of local laws and public safety.
Analysis:
This case is a landmark decision in the development of federal preemption doctrine, specifically 'field preemption.' It establishes that even where there is no direct conflict between a federal and state law, the state law is preempted if Congress has enacted a regulatory scheme so pervasive as to make reasonable the inference that Congress left no room for the States to supplement it. The Court's 'stands as an obstacle' test broadens the scope of preemption beyond explicit contradiction, focusing instead on whether state action interferes with the intended purposes and objectives of federal law. This principle is especially strong in areas of exclusive federal authority, such as foreign affairs and immigration, significantly limiting states' ability to legislate in these domains.
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