Edwards v. California

314 U.S. 160, 62 S. Ct. 164 (1941)

 

RULE:

The transportation of persons is "commerce," within the meaning of U.S. Const. art. I, § 8. It is nevertheless true that the states are not wholly precluded from exercising their police power in matters of local concern even though they may thereby affect interstate commerce. 

FACTS:

A resident of California brought his brother in-law from Texas to California. His brother in-law was indigent, and a complaint was filed against him under Cal. Welf. & Inst. Code § 2615, which made it illegal for a person to knowingly bring a non-resident indigent into California. The Superior Court of California convicted the resident under the statute for bringing an indigent non-resident into California after it upheld that Cal. Welf. & Inst. Code § 2615 was a valid exercise of the police power of the State of California. The case was appealed to the Supreme Court of the United States.

ISSUE:

Was the statute valid?

ANSWER:

No

CONCLUSION:

On certiorari review, the United States Supreme Court held that the statute was an unconstitutional barrier to interstate commerce, as it conflicted with the Commerce Clause, U.S. Const. art. I, § 8. The Commerce Clause had been interpreted to include the transportation of persons as commerce. Additionally, indigent non-residents who entered California were deprived of the opportunity to exert political pressure upon the California legislature to obtain a change in policy. Defendant's conviction under the statute could not be sustained.

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