Coyle v. Smith
E261350
Coyle v. Smith was a 1911 U.S. Supreme Court case that held Congress cannot dictate the permanent location of a state’s capital as a condition of its admission to the Union, affirming the equal footing of new states with existing ones.
All labels observed (2)
| Label | Occurrences |
|---|---|
| Coyle v. Smith canonical | 1 |
| Coyle v. Smith, Secretary of State of the State of Oklahoma | 1 |
How this entity was disambiguated
This entity first appeared as the object of triple T2362427 — resolving that mention is where its identity was fixed. The disambiguator weighed these candidate entities and picked the highlighted one (or “None”, minting a new entity). This is how homonymy is resolved: the same surface form can point to different entities.
NED1
Entity disambiguation (via context triple)
gpt-5-mini-2025-08-07
Target entity: Coyle v. Smith Context triple: [Admissions Clause, appliedInCase, Coyle v. Smith]
-
A.
McDonald v. Smith
McDonald v. Smith is a 1985 U.S. Supreme Court case that held the First Amendment’s Petition Clause does not grant absolute immunity from libel suits for statements made in petitions to government officials.
-
B.
Cooper v. Aaron
Cooper v. Aaron is a landmark 1958 U.S. Supreme Court decision affirming the supremacy of federal law and the Court’s authority by ruling that states are bound to enforce desegregation under Brown v. Board of Education.
-
C.
Corfield v. Coryell
Corfield v. Coryell is an 1823 federal circuit court decision by Justice Bushrod Washington that famously articulated an influential early list of the fundamental rights protected by the U.S. Constitution’s Privileges and Immunities Clause.
-
D.
Ray v. Blair
Ray v. Blair is a 1952 U.S. Supreme Court case that upheld a state's authority to require presidential electors to pledge support for their party's nominees as a condition of appointment.
-
E.
Briggs v. Elliott
Briggs v. Elliott was a landmark federal court case from South Carolina challenging racial segregation in public schools, and it became one of the key cases consolidated into Brown v. Board of Education.
- F. None of above. chosen
- G. Unsure - the case is ambiguous/there is not enough information to decide.
NED2
Entity disambiguation (via description)
gpt-5-mini-2025-08-07
Target entity: Coyle v. Smith Target entity description: Coyle v. Smith was a 1911 U.S. Supreme Court case that held Congress cannot dictate the permanent location of a state’s capital as a condition of its admission to the Union, affirming the equal footing of new states with existing ones.
-
A.
McDonald v. Smith
McDonald v. Smith is a 1985 U.S. Supreme Court case that held the First Amendment’s Petition Clause does not grant absolute immunity from libel suits for statements made in petitions to government officials.
-
B.
Cooper v. Aaron
Cooper v. Aaron is a landmark 1958 U.S. Supreme Court decision affirming the supremacy of federal law and the Court’s authority by ruling that states are bound to enforce desegregation under Brown v. Board of Education.
-
C.
Corfield v. Coryell
Corfield v. Coryell is an 1823 federal circuit court decision by Justice Bushrod Washington that famously articulated an influential early list of the fundamental rights protected by the U.S. Constitution’s Privileges and Immunities Clause.
-
D.
Ray v. Blair
Ray v. Blair is a 1952 U.S. Supreme Court case that upheld a state's authority to require presidential electors to pledge support for their party's nominees as a condition of appointment.
-
E.
Briggs v. Elliott
Briggs v. Elliott was a landmark federal court case from South Carolina challenging racial segregation in public schools, and it became one of the key cases consolidated into Brown v. Board of Education.
- F. None of above. chosen
Statements (42)
| Predicate | Object |
|---|---|
| instanceOf |
United States Supreme Court case
ⓘ
federal courts case ⓘ |
| areaOfLaw |
United States federalism jurisprudence
ⓘ
constitutional law ⓘ |
| citation | 221 U.S. 559 ⓘ |
| concernedCity |
Guthrie
ⓘ
surface form:
Guthrie, Oklahoma
Oklahoma City, Oklahoma, United States ⓘ
surface form:
Oklahoma City, Oklahoma
|
| constitutionalPrinciple | equal footing of states ⓘ |
| constitutionalProvisionInvolved | Article IV, Section 3, Clause 1 of the United States Constitution ⓘ |
| country |
United States of America
ⓘ
surface form:
United States
|
| courtOpinionType | majority opinion ⓘ |
| decisionDate | 1911-05-29 ⓘ |
| decisionStatus | good law ⓘ |
| factualBackground |
Congress, in the Oklahoma Enabling Act, attempted to require that the state capital remain at Guthrie until 1913
ⓘ
The Oklahoma legislature and voters approved moving the capital from Guthrie to Oklahoma City before 1913 ⓘ |
| fullCaseName |
Coyle v. Smith
self-linksurface differs
ⓘ
surface form:
Coyle v. Smith, Secretary of State of the State of Oklahoma
|
| hasJurisdiction |
Supreme Court of the United States
ⓘ
surface form:
United States Supreme Court
|
| holding |
Congress cannot dictate the permanent location of a state’s capital as a condition of its admission to the Union
ⓘ
New states enter the Union on an equal footing with existing states regarding powers of local self-government ⓘ |
| impact |
limited Congress’s ability to impose permanent restrictions on core state governmental powers as conditions of admission
ⓘ
reinforced the doctrine that new states have the same sovereignty as original states ⓘ |
| languageOfProceeding | English ⓘ |
| legalIssue |
equal footing doctrine
ⓘ
location of a state capital ⓘ power of Congress over conditions of state admission ⓘ |
| originatingState | Oklahoma ⓘ |
| pageInUnitedStatesReports | 559 ⓘ |
| petitioner | Coyle ⓘ |
| precedentFor |
cases involving state equality in the Union
ⓘ
cases limiting congressional conditions on state admission ⓘ |
| respondent | Smith ⓘ |
| respondentPosition | Secretary of State of Oklahoma ⓘ |
| result |
Oklahoma Organic Act
ⓘ
surface form:
Oklahoma was held free to choose the location of its capital
|
| shortDescription | 1911 U.S. Supreme Court decision on Congress’s inability to fix a state capital’s permanent location as a condition of statehood ⓘ |
| stateAdmittedInvolved | Oklahoma ⓘ |
| statehoodActInvolved | Oklahoma Enabling Act ⓘ |
| topic |
admission of new states
ⓘ
federalism in the United States ⓘ limits on congressional power ⓘ state sovereignty ⓘ |
| volumeInUnitedStatesReports | 221 ⓘ |
| yearDecided | 1911 ⓘ |
How these facts were elicited
The pipeline generated the facts above by prompting gpt-5.1 with this entity's name + description and the instruction below.
Instruction
You are a knowledge base construction expert. Given a subject entity and a description of it, return factual statements that you know for the subject as a JSON list of dictionaries(triples), where keys must be "subject", "predicate" and "object". The number of facts may be very high, between 25 to 50 or more, for very popular subjects. For less popular subjects, the number of facts can be very low, like 5 or 10. # Requirements - If you don't know the subject at all, return an empty list. - If the subject is not a named entity, return an empty list. - Include at least one triple where predicate is "instanceOf". - Do not get too wordy. - Separate several objects into multiple triples with one object.
Input
Subject: Coyle v. Smith Description of subject: Coyle v. Smith was a 1911 U.S. Supreme Court case that held Congress cannot dictate the permanent location of a state’s capital as a condition of its admission to the Union, affirming the equal footing of new states with existing ones.
Referenced by (2)
Full triples — surface form annotated when it differs from this entity's canonical label.
this entity surface form:
Coyle v. Smith, Secretary of State of the State of Oklahoma