''Coyle v. Smith'', 221 U.S. 559 (1911), was a

Supreme Court of the United States The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all Federal tribunals in the United States, U.S. federal court cases, and over Stat ...

case that held that the newly created

state State most commonly refers to: * State (polity), a centralized political organization that regulates law and society within a territory **Sovereign state, a sovereign polity in international law, commonly referred to as a country **Nation state, a ...

Oklahoma Oklahoma ( ; Choctaw language, Choctaw: , ) is a landlocked U.S. state, state in the South Central United States, South Central region of the United States. It borders Texas to the south and west, Kansas to the north, Missouri to the northea ...

was permitted to move its

capital city A capital city, or just capital, is the municipality holding primary status in a country, state (polity), state, province, department (administrative division), department, or other administrative division, subnational division, usually as its ...

from Guthrie to

Oklahoma City Oklahoma City (), officially the City of Oklahoma City, and often shortened to OKC, is the List of capitals in the United States, capital and List of municipalities in Oklahoma, most populous city of the U.S. state of Oklahoma. The county seat ...

, notwithstanding the

Enabling Act An enabling act is a piece of legislation by which a legislative body grants an entity which depends on it (for authorization or legitimacy) for the delegation of the legislative body's power to take certain actions. For example, enabling act ...

provision that prohibited it from being moved from Guthrie until after 1913.

Background

In 1907, Oklahoma was admitted as a U.S. state. The new state's capital was located in Guthrie. Section 497 of the

Oklahoma Constitution The Constitution of the State of Oklahoma is the governing document of the United States, U.S. State of Oklahoma. Adopted in 1907, Oklahoma ratified the United States Constitution on November 16, 1907, as the 46th U.S. state. At its ratificatio ...

stated that the terms of the U.S. Congress's

enabling act An enabling act is a piece of legislation by which a legislative body grants an entity which depends on it (for authorization or legitimacy) for the delegation of the legislative body's power to take certain actions. For example, enabling act ...

of 1906—which allowed Oklahoma to create a state constitution and be admitted to the Union—were "accepted by ordinance irrevocable". Section 2 of the enabling act read:

The capital of said state shall temporarily be at the city of Guthrie ... and shall not be changed therefrom previous to Anno Domini nineteen hundred and thirteen; but said capital shall, after said year, be located by the electors of said state at an election to be provided for by the legislature; ...

On December 29, 1910, the state of Oklahoma enacted a statute which removed the state capital from Guthrie to Oklahoma City. W.H. Coyle, owner of large property interests in Guthrie, sued the state of Oklahoma, arguing that the move was performed in violation of the state constitution's acceptance of the terms of Congress's enabling act.

Holding

The Supreme Court held that preventing the state of Oklahoma the right to locate its own seat of government deprived it of powers which all other states of the Union enjoyed, and thus violated the traditional constitutional principle that all new states be admitted "on an

equal footing The equal footing doctrine, also known as equality of the states, is the principle in United States constitutional law that all states admitted to the Union under the Constitution since 1789 enter on equal footing with the 13 states already in ...

with the original states". As a result, the provision of the enabling act which temporarily restricted Oklahoma's right to determine where its seat of government was no longer valid after Oklahoma was actually admitted. As stated by Justice Lurton:

Has Oklahoma been admitted upon an equal footing with the original states? If she has, she, by virtue of her jurisdictional sovereignty as such a state, may determine for her own people the proper location of the local seat of government. She is not equal in power to them if she cannot.At p. 579.

Quoting Chief Justice Chase's opinions regarding the indestructibility of the Union and the principle of federalism contained in '' Texas v. White'' and '' Lane County v. Oregon'', the opinion concludes:

To this we may add that the constitutional equality of the States is essential to the harmonious operation of the scheme upon which the Republic was organized. When that equality disappears, we may remain a free people, but the Union will not be the Union of the Constitution.

Notes

External links

* {{DEFAULTSORT:Coyle V. Smith Legal history of Oklahoma History of Oklahoma City Equal footing doctrine 1911 in United States case law 1911 in Oklahoma Logan County, Oklahoma United States Supreme Court cases United States Supreme Court cases of the White Court Guthrie, Oklahoma Former state capitals in the United States

Background

Holding

See also

Notes

External links