Edwards v. People of State of California
Decided on Nov. 24, 1941; 314 US 160


I. ISSUES II. CASE SUMMARY III. AMICI CURIAE IV. DECISION V. WIN OR LOSS?
I. ISSUES:

A. Issues Discussed: Interstate commerce

B. Legal Question Presented:

Is the prohibition embodied in Section 2615 of the Welfare and Institutions Code of California against the 'bringing' or transportation of indigent persons into California, within the police power of that State?

II. CASE SUMMARY:

A. Background:

Appellant, a resident of California, brought back from Texas to California his indigent brother-in-law. 

"A complaint was filed against appellant under Section 2615 of the Welfare and Institutions Code of California, St.1937, p. 1406, which provides: 'Every person, firm or corporation, or officer or agent thereof that brings or assists in bringing into the State any indigent person who is not a resident of the State, knowing him to be an indigent person, is guilty of a misdemeanor...' 

[A]ppellant was convicted and sentenced to six months imprisonment in the county jail, and sentence was suspended... [T]he Superior Court of Yuba County, although regarding as 'close' the question of the validity of the Section, felt 'constrained to uphold the statute as a valid exercise of the police power of the State of California'. Consequently, the conviction was affirmed."

The US Supreme Court reversed the judgment of the Superior Court.

B. Counsel of Record:
ACLU Side
(Petitioner/Appellant)
Opposing Side
(Respondent/Appellee)
Unavailable Unavailable
C. The Arguments:
ACLU Side
(Petitioner/Appellant)
Opposing Side
(Respondent/Appellee)
Unavailable Unavailable
III. AMICI CURIAE:
ACLU Side
(Petitioner/Appellant)
Opposing Side
(Respondent/Appellee)
Mr. Samuel Slaff, of New York City, for appellant. Mr. John H. Tolan, of Oakland, Cal., for the Select Committee of the House of Representatives of the United States, appointed pursuant to House Resolution No. 63, April 22, 1940, to investigate Interstate Migration of Destitute Citizens, as amicus curiae by special leave of Court.  Mr. W. T. Sweigert, of San Francisco, Cal., for appellee.
IV. THE SUPREME COURT'S DECISION:

"We think this statute must fail under any known test of the validity of State interference with interstate commerce...

The prohibition against transporting indigent non-residents into one State is an open invitation to retaliatory measures, and the burdens upon the transportation of such persons become cumulative... [W]e do not think that it will now be seriously contended that because a person is without employment and without funds he constitutes a 'moral pestilence'. Poverty and immorality are not synonymous.

We are of the opinion that Section 2615 is not a valid exercise of the police power of California, that it imposes an unconstitutional burden upon interstate commerce, and that the conviction under it cannot be sustained."

The US Supreme Court reversed the judgment of the Superior Court.

Justice Vote: 9 Pro vs. 0 Con

  • Byrnes, J.Pro (Wrote majority opinion)
  • Reed, S.  Pro (Joined majority opinion)
  • Frankfurter, I.  Pro (Joined majority opinion)
  • Store, H.  Pro (Joined majority opinion)
  • Roberts, O.  Pro (Joined majority opinion)
  • Douglas, W. Pro (Wrote concurring opinion)
  • Black, H. Pro (Joined concurring opinion)
  • Murphy, F. Pro (Joined concurring opinion)
  • Jackson, R. Pro (Wrote concurring opinion)

V. A WIN OR LOSS FOR THE ACLU?

The ACLU, as counsel of record, urged reversal of the judgment of the Superior Court; the Supreme Court reversed the lower court's ruling in a 9-0 vote, giving the ACLU an apparent win.