Coyle v. Smith, 221 U.S. 559; 31 S. Ct. 688; 55 L. Ed. 853 (1911)

Coyle v. Smith, 221 U.S. 559; 31 S. Ct. 688; 55 L. Ed. 853 (1911)

Facts—When Oklahoma was admitted as a state in 1907, Congress provided that the capital should be located at Guthrie until the year 1913. In 1910 the Oklahoma legislature provided for the removal of the capital to Oklahoma City.

Questions—(a) May Congress, under penalty of denying admission, impose limitations on a new state at the time of admission? (b) Will those limitations be binding after admission as a state?

Decisions—(a) Yes; (b) No.

ReasonsJ. Lurton (7–2). (a) “The constitutional provisions concerning the admission of new states is not a mandate, but a power to be exercised with discretion.” Therefore, Congress, in the exercise of this discretion, may impose conditions that a state-to-be must meet before Congress grants approval to its admission.

(b) Any restraints imposed by Congress on a new state before its admission can be ignored with impunity by that state after admission except such as have some bases in the Constitution. Congress has no power to limit the rights of a state. The constitutional duty of guaranteeing to each state a republican form of government does not allow Congress to place limits on them that would deprive them of equality with other states. The constitutional power of admission of states is based on the assumption that the new states will be on a par with other states. This is a union of equal states. If Congress could lay down binding conditions, as the one involved in this case on an incoming state, then the United States would include states unequal in power. When a state enters the Union, it at once becomes “entitled to and possessed of all the rights of dominion and sovereignty which belonged to the original states. She was admitted, and could be admitted, only on the same footing with them.”

A clear distinction should be drawn between a matter involving political inequality of a new state (as here, and which is not binding after admission) and a matter involving a quid pro quo contractual relation (which is binding after admission).

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