Tuesday, November 5, 2013

Hines, Secretary of Labor & Industry of Pennsylvania v. Davidowitz case brief

Hines, Secretary of Labor & Industry of Pennsylvania v. Davidowitz case brief summary
312 U.S. 52 (1941)

CASE SYNOPSIS
Appellant, the State of Pennsylvania, sought review by certiorari of a decision of a three-judge panel of the United States District Court for the Middle District of Pennsylvania, restraining state officials from enforcing the provisions of the Pennsylvania Alien Registration Act of 1939, Pa. Stat. Ann. tit. 35, §§ 1801-1806 (1939).

CASE FACTS
The State challenged a three-judge district court panel's decision enjoining enforcement of the Pennsylvania Alien Registration Act of 1939, Pa. Stat. Ann. tit. 35, §§ 1801-1806 (1939). The Court held that both the Pennsylvania act and the recently enacted federal Alien Registration Act, 54 Stat. 670, ch. 439 (1940), set forth a comprehensive scheme for registering aliens living in the United States.

DISCUSSION
  • The Court held that the State's power to legislate in the area of foreign relations was subordinate to the federal government's power to do so under the Supremacy Clause of the United States Constitution. 
  • Because the federal government had already enacted a comprehensive scheme, the state statute had been preempted. The Court affirmed.

CONCLUSION

The Court affirmed the judgment.

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