Johnson v. Maryland
1920 U.S. LEXIS 1236, 41 S. Ct. 16, 254 U.S. 51 (1920)
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Rule of Law:
A state cannot require a federal employee to obtain a state license as a prerequisite to performing their official duties, as such a requirement constitutes an unconstitutional interference with the instrumentalities of the United States government.
Facts:
- An employee of the United States Post Office Department was assigned to drive a government motor truck.
- The employee's official duties involved transporting mail over a post road from Mt. Airy, Maryland, to Washington.
- While driving the truck in Maryland as part of his job, the employee was arrested by state authorities.
- The arrest was for operating the vehicle without having obtained a driver's license from the State of Maryland, which required an examination and a fee.
Procedural Posture:
- An employee of the U.S. Post Office Department was tried and convicted in a Maryland state court for driving without a state-issued license while on duty.
- The employee raised constitutional challenges at trial through a motion to quash, special pleas, and a motion in arrest of judgment, all of which the trial court overruled.
- After the conviction was presumably upheld by Maryland's appellate courts, the employee (as plaintiff in error) sought review from the Supreme Court of the United States.
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Issue:
Does a state law requiring a federal employee to pass an examination and pay a fee for a driver's license before operating a government vehicle in the performance of official duties unconstitutionally interfere with the functions of the federal government?
Opinions:
Majority - Mr. Justice Holmes
Yes. A state law requiring a federal employee to obtain a state driver's license to perform their official duties is an unconstitutional interference with the federal government. The principle established in McCulloch v. Maryland dictates that states have an 'entire absence of power' to directly interfere with or control the instrumentalities of the United States. While federal employees are subject to general state laws that only incidentally affect their duties, such as traffic ordinances, a licensing requirement is a direct interference. It 'lays hold of them in their specific attempt to obey orders' and imposes qualifications in addition to those the federal government has deemed sufficient for its own operations. The Court presumes the federal government has performed its duty to employ competent individuals, and a state cannot second-guess that determination through its own licensing scheme.
Dissenting - Mr. Justice Pitney and Mr. Justice McReynolds
Mr. Justice Pitney and Mr. Justice McReynolds dissent.
Analysis:
This decision solidifies the doctrine of intergovernmental immunity, clarifying that state regulations cannot impose a prior restraint, such as a licensing requirement, on federal employees carrying out their official duties. It establishes a critical distinction between permissible, generally applicable state laws (e.g., traffic rules) and impermissible direct interference with federal functions. The ruling protects the operational autonomy of the federal government, preventing states from using their regulatory power to effectively veto or qualify the federal government's selection and deployment of its agents. This precedent ensures that federal operations are not subject to the approval or control of individual state officers.
