Edwards v. California (1941)

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In Edwards v. California (1941), the U.S. Supreme Court invalidated California’s “anti-Okie” law, which had made it a crime to bring an indigent person, who was not a resident of California, into that state. The purpose of the law was to prevent those who had lost everything when severe drought hit the Southwest from coming into California and becoming a drain on the state’s resources. A unanimous Court, speaking through Justice James Byrnes, invalidated the law, calling it an unconstitutional obstruction to interstate commerce. Four justices—William Douglas, Hugo Black, Frank Murphy, and Robert Jackson—concurred, agreeing with the outcome but for a different reason. They felt the law abridged the right to move about freely in the country, which is a privilege of U.S. citizenship protected against state infringement by the Privileges and Immunities Clause of the Fourteenth Amendment.

Robert W. Langran

Last updated: 2006

SEE ALSO: Dunn v. Blumstein; Privileges and Immunities Clause: Fourteenth Amendment