''Coyle v. Smith'', 221 U.S. 559 (1911), was a
Supreme Court of the United States
The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...
case that held that the newly created
state
State may refer to:
Arts, entertainment, and media Literature
* ''State Magazine'', a monthly magazine published by the U.S. Department of State
* ''The State'' (newspaper), a daily newspaper in Columbia, South Carolina, United States
* ''Our S ...
of
Oklahoma
Oklahoma (; Choctaw language, Choctaw: ; chr, ᎣᎧᎳᎰᎹ, ''Okalahoma'' ) is a U.S. state, state in the South Central United States, South Central region of the United States, bordered by Texas on the south and west, Kansas on the nor ...
was permitted to move its
capital city
A capital city or capital is the municipality holding primary status in a country, state, province, Department (country subdivision), department, or other subnational entity, usually as its seat of the government. A capital is typically a city ...
from
Guthrie to
Oklahoma City
Oklahoma City (), officially the City of Oklahoma City, and often shortened to OKC, is the capital and largest city of the U.S. state of Oklahoma. The county seat of Oklahoma County, it ranks 20th among United States cities in population, a ...
, notwithstanding the
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 car ...
provision that prohibited it from being moved from Guthrie until after 1913.
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 stated that the terms of the U.S. Congress's
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 car ...
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 was no longer valid after Oklahoma was actually admitted. As stated by 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.[At p. 579.]
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'', 74 U.S. (7 Wall.) 700 (1869), was a 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 ill ...
'' 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. "
See also
*
List of United States Supreme Court cases, volume 221
This is a list of cases reported in volume 221 of ''United States Reports'', decided by the Supreme Court of the United States in 1911.
Justices of the Supreme Court at the time of volume 221 U.S.
The Supreme Court is established by Ar ...
*
Symmetric federalism Symmetric federalism refers to a federal system of government in which each constituent state to the federation possess equal powers. In a symmetric federalism no distinction is made between constituent states. This is in contrast to asymmetric fede ...
Notes
External links
*
{{DEFAULTSORT:Coyle V. Smith
Legal history of Oklahoma
History of Oklahoma
History of Oklahoma City
Equal footing doctrine
1911 in United States case law
1911 in Oklahoma
Logan County, Oklahoma
United States Supreme Court cases
United States Supreme Court cases of the White Court
Guthrie, Oklahoma
Former state capitals in the United States