Edwards v. California

E507014

Edwards v. California is a 1941 U.S. Supreme Court case that struck down a California law restricting the bringing of indigent persons into the state, holding that such limits on interstate movement violated the Commerce Clause.

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Statements (49)

Predicate Object
instanceOf Commerce Clause case
United States Supreme Court case
arguedDate 1941-11-06
citation 314 U.S. 160
constitutionalProvisionInterpreted Article I, Section 8, Clause 3 of the United States Constitution NERFINISHED
Commerce Clause of the United States Constitution NERFINISHED
country United States of America
surface form: United States
court Supreme Court of the United States
decisionDate 1941-11-24
decisionType plenary decision
effectOnLaw limited state power to exclude indigent migrants from entering the state.
fullName Edwards v. California NERFINISHED
holding A state may not bar the transportation of indigent persons into the state because such a restriction is an unconstitutional burden on interstate commerce.
California Welfare and Institutions Code § 2615, prohibiting knowingly bringing an indigent person into California, violates the Commerce Clause of the U.S. Constitution.
issue Whether California may restrict the interstate movement of indigent persons.
Whether a state law criminalizing the transportation of indigent nonresidents into the state violates the Commerce Clause.
joinedByMajority Chief Justice Harlan F. Stone NERFINISHED
Justice Felix Frankfurter NERFINISHED
Justice Frank Murphy NERFINISHED
Justice Hugo L. Black NERFINISHED
Justice Owen J. Roberts NERFINISHED
Justice Robert H. Jackson NERFINISHED
Justice Stanley F. Reed NERFINISHED
Justice William O. Douglas NERFINISHED
jurisdiction United States federal jurisdiction NERFINISHED
lawChallenged California Welfare and Institutions Code § 2615 NERFINISHED
lawChallengedDescription California statute making it a misdemeanor to knowingly bring or assist in bringing an indigent person into the state.
majorityOpinionBy Justice James F. Byrnes NERFINISHED
pageInUnitedStatesReports 160
party Edwards NERFINISHED
State of California NERFINISHED
petitioner Edwards NERFINISHED
priorHistory People v. Edwards, 35 Cal. App. 2d 673, 96 P.2d 379 (Cal. Ct. App. 1939) NERFINISHED
respondent California NERFINISHED
result California statute restricting the bringing of indigent persons into the state was struck down.
separateOpinion concurrence by Justice Felix Frankfurter
concurrence by Justice Harlan F. Stone
concurrence by Justice Robert H. Jackson
concurrence by Justice William O. Douglas
significance considered an important step toward recognition of a constitutional right to interstate travel.
recognized that the movement of persons is a form of interstate commerce protected from undue state burdens.
subjectMatter constitutional limits on state regulation of interstate movement of persons
federalism and state police powers
topic indigency and poverty laws
interstate commerce
right to travel between states
state regulation of migration
volumeOfUnitedStatesReports 314
yearDecided 1941

Referenced by (1)

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