Coyle v. Smith

Coyle v. Oklahoma made it clear the states were politically equal by denying Congress the power, in granting statehood to territories, to withhold any of the powers and functions that belong to states.

All states are equal, but those that formed "a more perfect Union" first have sometimes tried to withhold powers that properly belong to states from territories seeking admission or seceding states wanting readmission.

The Supreme Court put a stop to the practice in a case in which the territory of Oklahoma had "irrevocably" agreed in 1906 to locate its capital in the town of Guthrie. In 1910, however, the people of Oklahoma, through a popular initiative, decided the capital should be moved forthwith from Guthrie to Oklahoma City and allocated $600,000 for public buildings there.

Congress apparently had not learned from previous cases involving Texas and Alabama, in which the Supreme Court had overturned conditions set by Congress in return for statehood status. Indeed, more substantive concerns were at issue in those cases which had been decided in favor of the states. In the 1845 case of Alabama, Congress had demanded the new state cede ownership of the submerged lands under its navigable waters to the federal government. Congress wanted to keep the waters open as public highways, but the Court found the intention could not override common-law title all states shared in submerged lands. Alabama was entitled to the same "sovereignty and jurisdiction," the Court ruled:

To maintain any other doctrine is to deny Alabama has been admitted to the Union on an equal footing with the other states.

In 1865, Texas, still "unreconstructed" after the Civil War, claimed payment of $5 million in bonds pledged in 1850 by the United States to Texas, redeemable on 31 December 1864. Texas no longer had legal standing, however, federal attorneys argued, because the state, after seceding, was no longer a "state" within the meaning of the Constitution. The Court disagreed, saying secession was constitutionally impossible:

The Constitution, in all of its provisions, looks to an indestructible union, composed of indestructible states.

Consequently, when Coyle v. Oklahoma came before the bench, Justice Lurton ruled the only question was whether the "restriction was a valid limitation upon the power of the state." Although Lurton produced relatively few opinions as a Supreme Court justice, he was respected as common law authority:

"This Union" was and is a union of states, equal in power, dignity and authority . . . That one of the original thirteen states could now be shorn of such powers by an act of Congress would not now for a moment be entertained.

The constitutional equality of the states, Lurton concluded "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."