Edwards v. California, 314 U.S. 160; 62 S. Ct. 164; 86 L. Ed. 119 (1941)

Facts—Edwards was a citizen of the United States and a resident of California. He left Marysville, California, for Spur, Texas, with the intention of bringing his wife’s brother, Frank Duncan, to Marysville. Duncan was a resident of Texas. Edwards knew that Duncan was employed by the Work Projects Administration and that he was indigent. They traveled in Edwards’s car. Duncan had about $20 when he left Texas and nothing when he arrived in California. He lived unemployed with Edwards for ten days, then received assistance from the Farm Security Administration. The District Court decided that Edwards violated the Welfare and Institutions Code of California by knowingly bringing a nonresident indigent person into the state.

Question—Is this law banning persons from knowingly bringing an individual into the state a valid exercise of the police power of the state of California?

Decision—No.

Reasons—J. Byrnes (9–0). The California statute concerning the entry of indigent persons violated the commerce clause of the federal Constitution. The passage of persons from state to state constitutes interstate commerce within the provisions of Article I, Section 8 of the Constitution delegating to Congress the authority to regulate interstate commerce, and the California law imposed an unconstitutional burden on such commerce. The concurring opinion noted that the right to move freely from state to state is an incident of national citizenship protected by the privileges and immunities clause of the Fourteenth Amendment against state interference.