Saturday, December 7, 2013

Missouri v. Holland case brief

Missouri v. Holland case brief summary
252 U.S. 416 (1920)


CASE SYNOPSIS
Appellant State of Missouri sought review of a decision of the District Court of the United States for the Western District of Missouri, which dismissed the State's action against appellee United States Game Warden challenging a migratory bird treaty.

CASE FACTS
The State brought a bill in equity, which challenged the Migratory Bird Treaty Act of July 3, 1918, 40 Stat. 755, and the regulations made by the Secretary of Agriculture in pursuance of the same, claiming that the treaty was an unconstitutional interference with appellant's sovereign rights under the Tenth Amendment, which included absolute control of wild game and birds within the State's borders. The State also alleged a pecuniary interest, as owner of the wild birds within its borders. The district court dismissed the action on the ground that the act of Congress was constitutional.

DISCUSSION
  • On appeal to the United States Supreme Court, the Court affirmed the dismissal, concluding that the power to make the treaty had been expressly delegated to the United States under U.S. Constitutional art. II, § 2 and art. VI. 
  • The Court noted that the treaty did not contravene any prohibitory words found in the federal constitution, nor was the subject matter, the regulation of migratory birds, forbidden by some invisible radiation from the general terms of the Tenth Amendment. 
  • Rejecting the State's claim upon title, the Court stated that the wild birds were not in the possession of anyone.

CONCLUSION
The court affirmed the judgment dismissing the action, holding that in pursuance of a valid treaty, the government could constitutionally regulate the killing of migratory birds.

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