Coyle v. Smith
Encyclopedia
Coyle v. Smith, , was a Supreme Court of the United States
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...

 case that held that the newly created state
U.S. state
A U.S. state is any one of the 50 federated states of the United States of America that share sovereignty with the federal government. Because of this shared sovereignty, an American is a citizen both of the federal entity and of his or her state of domicile. Four states use the official title of...

 of Oklahoma
Oklahoma
Oklahoma is a state located in the South Central region of the United States of America. With an estimated 3,751,351 residents as of the 2010 census and a land area of 68,667 square miles , Oklahoma is the 28th most populous and 20th-largest state...

 was permitted to move its capital city
Capital City
Capital City was a television show produced by Euston Films which focused on the lives of investment bankers in London living and working on the corporate trading floor for the fictional international bank Shane-Longman....

 from Guthrie
Guthrie, Oklahoma
Guthrie is a city in and the county seat of Logan County, Oklahoma, United States, and a part of the Oklahoma City Metroplex. The population was 9,925 at the 2000 census.Guthrie was the territorial and later the first state capital for Oklahoma...

 to Oklahoma City
Oklahoma city
Oklahoma City is the capital and largest city of the U.S. state of Oklahoma.Oklahoma City may also refer to:*Oklahoma City metropolitan area*Downtown Oklahoma City*Uptown Oklahoma City*Oklahoma City bombing*Oklahoma City National Memorial...

, notwithstanding a state constitution
Constitution
A constitution is a set of fundamental principles or established precedents according to which a state or other organization is governed. These rules together make up, i.e. constitute, what the entity is...

al provision that prohibited it from being moved out of Guthrie.

Background

In 1907, Oklahoma was admitted as a U.S. state. The new state's capital was located in Guthrie. Section 497 of the Oklahoma Constitution
Oklahoma Constitution
The Constitution of the State of Oklahoma is the governing document of the U.S. State of Oklahoma. Adopted in 1907, Oklahoma ratified the United States Constitution on November 16, 1907, as the 46th US State. At its ratification, the Oklahoma Constitution was the longest governing document of any...

 stated that the terms of the U.S. Congress's enabling act
Enabling act
An enabling act is a piece of legislation by which a legislative body grants an entity which depends on it for authorization or legitimacy the power to take certain actions. For example, enabling acts often establish government agencies to carry out specific government policies in a modern nation...

 of 1906—which allowed Oklahoma to create a state constitution and be admitted to the Union—were "accepted by ordinance irrevocable". Section 2 of the enabling act read:


The capital of said state shall temporarily be at the city of Guthrie ... and shall not be changed therefrom previous to Anno Domini nineteen hundred and thirteen; but said capital shall, after said year, be located by the electors of said state at an election to be provided for by the legislature; ...


On December 29, 1910, the state of Oklahoma enacted a statute which removed the state capital from Guthrie to Oklahoma City. W.H. Coyle, owner of large property interests in Guthrie, sued the state of Oklahoma, arguing that the move was performed in violation of the state constitution's acceptance of the terms of Congress's enabling act.

Holding

The Supreme Court held that preventing the state of Oklahoma the right to locate its own seat of government deprived it of powers which all other states of the Union enjoyed, and thus violated the traditional constitutional principle that all new states be admitted "on an equal footing with the original states". As a result, the provision of the enabling act which temporarily restricted Oklahoma's right to determine where its seat of government would be was unconstitutional. As stated by Mr. Justice Lurton:


Has Oklahoma been admitted upon an equal footing with the original states? If she has, she, by virtue of her jurisdictional sovereignty as such a state, may determine for her own people the proper location of the local seat of government. She is not equal in power to them if she cannot.


Quoting Chief Justice Chase's opinions regarding the indestructibility of the Union and the principle of federalism contained in Texas v. White
Texas v. White
Texas v. White, was a significant case argued before the United States Supreme Court in 1869. The case involved a claim by the Reconstruction government of Texas that United States bonds owned by Texas since 1850 had been illegally sold by the Confederate state legislature during the American...

 and Lane County v. Oregon, the opinion concludes:


To this we may add that the constitutional equality of the States is essential to the harmonious operation of the scheme upon which the Republic was organized. When that equality disappears, we may remain a free people, but the Union will not be the Union of the Constitution. "
The source of this article is wikipedia, the free encyclopedia.  The text of this article is licensed under the GFDL.
 
x
OK