Talk:Coyle v. Smith

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Law

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Oklahoma Mid‑importance

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Findings[edit]

I have just edited this article to rewrite the findings, specifically to remove the claim that the restriction was "unconstitutional" as well as the statement in the infobox that the decision invalidated part of the Oklahoma Constitution. A careful reading of the opinion shows that both claims are false.

A more complete statement of the Court's findings are as follows: Congress, under its plenary and discretionary authority to admit new states, was allowed in the 1906 Oklahoma Enabling Act to condition Oklahoma's admission on its accepting a condition that it not move its capital from Guthrie before 1913; however, its constitutional power to impose such a condition expired when Oklahoma was admitted in 1907 by authority of that act. Even though the state constitutional convention accepted the condition by "ordinance irrevocable", after admission there was no longer any valid Federal authority to enforce it; thus as a sovereign state under the Constitution, Oklahoma had the inherent power to locate its state capital like all other states under the Equal Footing Doctrine. After admission, the Enabling Act's restriction was only enforceable as Oklahoma law thru the "ordinance irrevocable", not as Federal law thru the Enabling Act itself.

In 1910 Oklahoma repealed the "ordinance irrevocable" and moved its capital to Oklahoma City; that action was upheld as valid under Oklahoma law by the Oklahoma Supreme Court, and as a ruling under state law that was final and could not be reversed even by SCOTUS. The appeal of that decision to SCOTUS was based solely on the state court's additional finding that the Enabling Act was no longer binding on Oklahoma; SCOTUS agreed and affirmed that finding. (I also added "Oklahoma Supreme Court affirmed" to the infobox.)

A similar result occurred when Congress, in Arizona's act of admission (passed after Oklahoma's but before this decision), conditioned its admission on exempting judges from the recall provision of the state constitution. Arizona did that and was admitted in 1912; but the very first amendment to its constitution after admission reinstated judicial recall, which remains the law in Arizona today. Also, though Utah has never repealed the provision in its constitution accepting Congress' 1896 condition of admission that it ban polygamy (also found in other acts of admission from that era), under this case there is no legal reason why Utah could not repeal that provision and bring back polygamy, though that is highly unlikely for multiple reasons (especially the mainstream LDS/Mormon church's repudiation of polygamy in 1890 which has held to this day).--RBBrittain (talk) 23:14, 27 January 2021 (UTC)[reply]