United States v. Wheeler
 | |
| United States v. Wheeler | |
| Reference: 254 U.S. 281 | |
| Term: 1920 | |
| Important Dates | |
| Argued: April 28, 1920 Decided: December 13, 1920 | |
| Outcome | |
| United States District Court for the District of Arizona affirmed | |
| Majority | |
| Edward Douglass White • Joseph McKenna • Oliver Wendell Holmes • William Rufus Day • Willis Van Devanter • Mahlon Pitney • James Clark McReynolds • Louis Brandeis | |
| Dissenting | |
| John Hessin Clarke | |
United States v. Wheeler is a case decided on December 13, 1920, by the United States Supreme Court holding that states have the power to prosecute individuals for wrongful interference with the right to travel. The case concerned whether the federal government had the authority to charge officials for kidnapping and deporting a group of miners from Bisbee, Arizona. The Supreme Court affirmed the ruling of the United States District Court for the District of Arizona.[1][2]
Why it matters: The Supreme Court's decision in this case established that the U.S. Constitution grants sole power to the states to prosecute individuals for wrongful interference with the right to travel. To read more about the impact of United States v. Wheeler click here.
Background
The Industrial Workers of the World labor union called for a strike against the mining companies in Bisbee, Arizona in June 1917. The efforts resulted in approximately half of the town's workforce on strike. In response, Sheriff Harry Wheeler and other law enforcement officers arrested over 1,000 miners, forced them by gunpoint into boxcars, and deported them to a desert in New Mexico without food or water. U.S. troops arrived shortly after and escorted the men to facilities in Columbus, New Mexico where they remained for months. During this time, Bisbee authorities stationed guards on the roads leading into the town to ensure that the miners could not return.
President Woodrow Wilson established the Federal Mediation Commission to investigate. The case was brought before the District Court for the District of Arizona, but it was dismissed on the grounds that no federal laws were broken. The Department of Justice filed a writ of error to the Supreme Court and the decision of the lower court was affirmed.[3][4]
Oral argument
Oral argument was held on April 28, 1920. The case was decided on December 13, 1920.[1]
Decision
The Supreme Court decided 8-1 to affirm the decision of the District Court for the District of Arizona. Chief Justice Edward Douglass White delivered the opinion of the court. Justice John Hessin Clarke dissented, but did not write an opinion.[1]
Opinions
Opinion of the court
Chief Justice Edward Douglass White, writing for the court, argued that states have the authority to enforce the Privileges and Immunities Clause of Article Four of the U.S. Constitution, as opposed to the federal government.[1]
| “ | That the Constitution plainly intended to preserve and enforce the limitation as to discrimination imposed upon the states by Article IV of the Confederation, and thus necessarily assumed the continued possession by the states of the reserved power to deal with free residence, ingress, and egress, cannot be denied for the following reasons: (1) because the text of Article IV, § 2, of the Constitution makes manifest that it was drawn with reference to the corresponding clause of the Articles of Confederation, and was intended to perpetuate its limitations, and (2) because that view has been so conclusively settled as to leave no room for controversy. [5] | ” |
| —Edward Douglass White, majority opinion in United States v. Wheeler[1] | ||
White also argued that the defendants did not violate any federal laws. White held that there is no federal authority to prosecute individuals for wrongful interference with the right to travel and that states maintain that power.[1]
| “ | Undoubtedly the right of citizens of the states to reside peacefully in, and to have free ingress into and egress from, the several states had, prior to the Confederation, a two-fold aspect: (1) as possessed in their own states, and (2) as enjoyed in virtue of the comity of other states. But, although the Constitution fused these distinct rights into one by providing that one state should not deny to the citizens of other states rights given to its own citizens, no basis is afforded for contending that a wrongful prevention by an individual of the enjoyment by a citizen of one state in another of rights possessed in that state by its own citizens was a violation of a right afforded by the Constitution. This is the necessary result of Article IV, § 2, which reserves to the several states authority over the subject, limited by the restriction against state discriminatory action, hence excluding federal authority except where invoked to enforce the limitation, which is not here the case -- a conclusion expressly sustained by the ruling in United States v. Harris, 106 U. S. 629, 106 U. S. 645, to the effect that the second section of Article IV, like the Fourteenth Amendment, is directed alone against state action. [5] | ” |
| —Edward Douglass White, majority opinion in United States v. Wheeler[1] | ||
Impact
| Federalism |
|---|
| •Key terms • Court cases •Major arguments • State responses to federal mandates • Federalism by the numbers • Index of articles about federalism |
United States v. Wheeler established that the U.S. Constitution grants power to the states to prosecute individuals for wrongful interference with the right to travel. The decision in this case impacted the view of the Privileges and Immunities Clause of Article Four of the U.S. Constitution. The clause states:
| “ | The Citizens of each State shall be entitled to all Privileges and Immunities of Citizens in the several States. [5] | ” |
| —United States Constitution[6] | ||
The ruling in this case altered the interpretation of the Privileges and Immunities Clause to establish that states had the sole power to enforce the clause.
See also
External links
- Full text of case syllabus and opinions (Justia)
- Supreme Court of the United States
- Search Google News for this topic
Footnotes
- ↑ 1.0 1.1 1.2 1.3 1.4 1.5 1.6 Justia, "United States v. Wheeler," accessed June 16, 2022
- ↑ Casetext, "United States v. Wheeler," accessed June 16, 2022
- ↑ Arizona State Library, Archives, & Public Records, "Bisbee Deportation," accessed June 16, 2022
- ↑ The Bisbee Deportation of 1917, "Overview," accessed June 16, 2022
- ↑ 5.0 5.1 5.2 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
- ↑ Constitution Annotated, "ArtIV.S2.C1.1 Historical Background on Privileges and Immunities Clause," accessed June 17, 2022
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