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State of Missouri v. Holland, 252 U.S. 416, 40 S.Ct. 382, 64 L.Ed. 641, 11 A.L.R. 984, 18 Ohio Law Rep. 61

Facts

The State of Missouri filed a suit against Ray P. Holland, the United States Game Warden, to stop the enforcement of the Migratory Bird Treaty Act of 1918. The State claimed that the Act infringed upon its rights reserved by the Tenth Amendment and that it had a pecuniary interest as the owner of the wild birds within its borders. The District Court dismissed the suit, ruling that the Act was constitutional, prompting the State to appeal the decision.

The State also alleges a pecuniary interest, as owner of the wild birds within its borders and otherwise, admitted by the Government to be sufficient, but it is enough that the bill is a reasonable and proper means to assert the alleged quasi sovereign rights of a State.

Issue

The main legal issue was whether the Migratory Bird Treaty Act and the associated regulations constituted an unconstitutional interference with the rights reserved to the States by the Tenth Amendment.

The ground of the bill is that the statute is an unconstitutional interference with the rights reserved to the States by the Tenth Amendment, and that the acts of the defendant done and threatened under that authority invade the sovereign right of the State and contravene its will manifested in statutes.

Rule

The court applied the principle that treaties made under the authority of the United States are the supreme law of the land, and that the power to make treaties is expressly delegated to the federal government, which can enact laws to enforce those treaties.

If the treaty is valid there can be no dispute about the validity of the statute under Article 1, Section 8, as a necessary and proper means to execute the powers of the Government.

Analysis

The court analyzed the relationship between state rights and federal treaty powers, concluding that while states may regulate the killing and sale of migratory birds, their authority is not exclusive. The court emphasized that the treaty and statute were necessary to protect a national interest that transcends state boundaries, particularly given the migratory nature of the birds involved.

The treaty in question does not contravene any prohibitory words to be found in the Constitution. The only question is whether it is forbidden by some invisible radiation from the general terms of the Tenth Amendment.

Conclusion

The court affirmed the District Court's decree, upholding the constitutionality of the Migratory Bird Treaty Act and the regulations made under it.

We are of opinion that the treaty and statute must be upheld.

Who won?

The United States prevailed in the case, as the court upheld the constitutionality of the Migratory Bird Treaty Act, determining that the federal government had the authority to regulate migratory birds despite state claims of exclusive rights.

The State appeals.

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