Hughes v. Oklahoma
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OR:

''Hughes v. Oklahoma'', 441 U.S. 322 (1979), was a
United States Supreme Court 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 ...
decision, which held that the
United States Congress The United States Congress is the legislature of the federal government of the United States. It is bicameral, composed of a lower body, the House of Representatives, and an upper body, the Senate. It meets in the U.S. Capitol in Washing ...
may enact legislation governing
wildlife Wildlife refers to undomesticated animal species, but has come to include all organisms that grow or live wild in an area without being introduced by humans. Wildlife was also synonymous to game: those birds and mammals that were hunted ...
on
federal lands Federal lands are lands in the United States owned by the federal government. Pursuant to the Property Clause of the United States Constitution ( Article 4, section 3, clause 2), Congress has the power to retain, buy, sell, and regulate federal l ...
.


Background

Oklahoma enacted statutes that prevented any person from selling
minnow Minnow is the common name for a number of species of small freshwater fish, belonging to several genera of the families Cyprinidae and Leuciscidae. They are also known in Ireland as pinkeens. Smaller fish in the subfamily Leusciscidae are c ...
s found within the natural waters of the state of Oklahoma outside of the state of Oklahoma. Oklahoma claimed that the purpose of the statute was for wildlife conservation. The underlying legal controversy arose when William Hughes was convicted of shipping minnows fished from Oklahoma waters out of the state.


Opinion of the Court

The Supreme Court held that the statute violated the
Dormant Commerce Clause The Dormant Commerce Clause, or Negative Commerce Clause, in American constitutional law, is a legal doctrine that courts in the United States have inferred from the Commerce Clause in Article I of the US Constitution. The primary focus of the d ...
because it discriminated the flow of interstate commerce without being the least discriminatory alternative. The Court stated that when conflicting state law exists, the
supremacy clause The Supremacy Clause of the Constitution of the United States ( Article VI, Clause 2) establishes that the Constitution, federal laws made pursuant to it, and treaties made under its authority, constitute the "supreme Law of the Land", and thu ...
ensures that federal legislation will prevail. The Court thereby overruled '' Geer v. Connecticut'' (1896), rejecting the earlier case's "19th century legal fiction of state ownership" of wildlife. In the Court's view, this "fiction" had "been eroded to the point of virtual extinction in cases involving regulation of wild animals." With the fall of ''Geer'', the last precedential impediment to the federal government's
wildlife management Wildlife management is the management process influencing interactions among and between wildlife, its habitats and people to achieve predefined impacts. It attempts to balance the needs of wildlife with the needs of people using the best availabl ...
authority was removed.


See also

*
List of United States Supreme Court cases, volume 441 This is a list of all the United States Supreme Court cases from volume 441 of the ''United States Reports The ''United States Reports'' () are the official record ( law reports) of the Supreme Court of the United States. They include rulings, ...


Further reading

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External links

* United States Supreme Court cases United States Supreme Court cases of the Burger Court United States environmental case law United States land use case law 1979 in the environment 1979 in United States case law Wildlife case law {{SCOTUS-case-stub