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 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of the enabling act which temporarily restricted Oklahoma's right to determine where its seat of government was no longer valid after Oklahoma was actually admitted.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. [1]
Quoting Chief Justice Chase's opinions regarding the indestructibility of the Union and the principle of federalism contained in Texas v. White 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. " [2]
Article One of the United States Constitution establishes the legislative branch of the federal government, the United States Congress. Under Article One, Congress is a bicameral legislature consisting of the House of Representatives and the Senate. Article One grants Congress various enumerated powers and the ability to pass laws "necessary and proper" to carry out those powers. Article One also establishes the procedures for passing a bill and places various limits on the powers of Congress and the states from abusing their powers.
Article Four of the United States Constitution outlines the relationship between the various states, as well as the relationship between each state and the United States federal government. It also empowers Congress to admit new states and administer the territories and other federal lands.
The Equal Rights Amendment (ERA) is a proposed amendment to the United States Constitution designed to guarantee equal legal rights for all American citizens regardless of sex. Proponents assert it would end legal distinctions between men and women in matters of divorce, property, employment, and other matters. The first version of an ERA was written by Alice Paul and Crystal Eastman and introduced in Congress in December 1923.
Guthrie is a city and county seat in Logan County, Oklahoma, United States, and a part of the Oklahoma City Metroplex. The population was 10,191 at the 2010 census, a 2.7 percent increase from the figure of 9,925 in the 2000 census.
Plessy v. Ferguson, 163 U.S. 537 (1896), was a landmark U.S. Supreme Court decision in which the Court ruled that racial segregation laws did not violate the U.S. Constitution as long as the facilities for each race were equal in quality, a doctrine that came to be known as "separate but equal". The decision legitimized the many state laws re-establishing racial segregation that had been passed in the American South after the end of the Reconstruction era (1865–1877).
United States v. Morrison, 529 U.S. 598 (2000), is a U.S. Supreme Court decision that held that parts of the Violence Against Women Act of 1994 were unconstitutional because they exceeded the powers granted to the US Congress under the Commerce Clause and the Fourteenth Amendment's Equal Protection Clause. Along with United States v. Lopez (1995), it was part of a series of Rehnquist Court cases that limited Congress's powers under the Commerce Clause.
In American political discourse, states' rights are political powers held for the state governments rather than the federal government according to the United States Constitution, reflecting especially the enumerated powers of Congress and the Tenth Amendment. The enumerated powers that are listed in the Constitution include exclusive federal powers, as well as concurrent powers that are shared with the states, and all of those powers are contrasted with the reserved powers—also called states' rights—that only the states possess.
The Enabling Act of 1802 was passed on April 30, 1802 by the Seventh Congress of the United States. This act authorized the residents of the eastern portion of the Northwest Territory to form the state of Ohio and join the U.S. on an equal footing with the other states. To accomplish this, and in doing so, the act also established the precedent and procedures for creation of future states in the western territories. The Enabling Act of 1802 would be the first appropriation by Congress for internal improvements in the country's interior.
The Equal Protection Clause is part of the first section of the Fourteenth Amendment to the United States Constitution. The clause, which took effect in 1868, provides "nor shall any State ... deny to any person within its jurisdiction the equal protection of the laws." It mandates that individuals in similar situations be treated equally by the law.
Federalism in the United States is the constitutional division of power between U.S. state governments and the federal government of the United States. Since the founding of the country, and particularly with the end of the American Civil War, power shifted away from the states and toward the national government. The progression of federalism includes dual, cooperative, and new federalism.
The enumerated powers of the United States Congress are the powers granted to the federal government of the United States by the United States Constitution. Most of these powers are listed in Article I, Section 8.
The Constitution of the State of Oklahoma is the governing document of the U.S. State of Oklahoma. Adopted in 1907, Oklahoma ratified the United States Constitution on November 16, 1907, as the 46th U.S. state. At its ratification, the Oklahoma Constitution was the most lengthy governing document of any government in the U.S. All U.S. state constitutions are subject to federal judicial review; any provision can be nullified if it conflicts with the U.S. Constitution.
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 federalism, where a distinction is made between constituent states.
In the United States, a state is a constituent political entity, of which there are 50. Bound together in a political union, each state holds governmental jurisdiction over a separate and defined geographic territory where it shares its sovereignty with the federal government. Due to this shared sovereignty, Americans are citizens both of the federal republic and of the state in which they reside. State citizenship and residency are flexible, and no government approval is required to move between states, except for persons restricted by certain types of court orders.
The equal footing doctrine, also known as equality of the states, is the principle in United States constitutional law that all states admitted to the Union under the Constitution since 1789 enter on equal footing with the 13 states already in the Union at that time. The Constitution grants to Congress the power to admit new states in Article IV, Section 3, Clause 1, which states:
New States may be admitted by the Congress into this Union; but no new State shall be formed or erected within the Jurisdiction of any other State; nor any State be formed by the Junction of two or more States, or Parts of States, without the Consent of the Legislatures of the States concerned as well as of the Congress.
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An Organic Act is a generic name for a statute used by the United States Congress to describe a territory, in anticipation of being admitted to the Union as a state. Because of Oklahoma's unique history an explanation of the Oklahoma Organic Act needs a historic perspective. In general, the Oklahoma Organic Act may be viewed as one of a series of legislative acts, from the time of Reconstruction, enacted by Congress in preparation for the creation of a unified State of Oklahoma. The Organic Act created Oklahoma Territory, and Indian Territory that were Organized incorporated territories of the United States out of the old "unorganized" Indian Territory. The Oklahoma Organic Act was one of several acts whose intent was the assimilation of the tribes in Oklahoma and Indian Territories through the elimination of tribes' communal ownership of property.
Ward v. Race Horse, 163 U.S. 504 (1896), is a United States Supreme Court case argued on March 11–12, 1896, and decided on 25 May 1896.
