## Facts

- Congress’s 1906 Oklahoma Enabling Act provided that the state capital would be temporarily at Guthrie and could not be changed before 1913, after which the location would be determined by popular election.
- Oklahoma was admitted as a state in 1907; its constitutional convention adopted an “ordinance irrevocable” accepting the Enabling Act’s terms.
- In 1910, Oklahoma enacted a statute relocating the capital immediately from Guthrie to Oklahoma City, contrary to the Enabling Act’s timing restriction.
- W.H. Coyle, a Guthrie landowner, claimed economic injury and sued the Oklahoma Secretary of State, arguing the move violated binding federal conditions accepted at statehood.
- The Oklahoma Supreme Court upheld the relocation statute; Coyle sought U.S. Supreme Court review.

## Issues

1. Whether Congress may, as a condition of admitting a new state, restrict for a fixed period the state’s power to choose and change the location of its seat of government.
2. Whether Oklahoma’s acceptance of the enabling-act terms as “irrevocable” made the capital-location restriction enforceable after statehood.

## Decision

- The Supreme Court affirmed the Oklahoma Supreme Court.
- Oklahoma entered the Union on an equal footing with existing states and therefore retained sovereign authority to locate and relocate its capital.
- The enabling-act provision restricting capital relocation was invalid after admission because it attempted to control a purely internal state function.
- The state’s “ordinance irrevocable” could not constitutionally surrender powers essential to state equality within the Union.

## Legal Principles

- Under the equal footing doctrine, new states must enter the Union with the same political sovereignty as the original states, including powers not delegated to the federal government.
- Congress may attach conditions to admission that operate within federal authority (e.g., public lands, Indian affairs, interstate commerce), and such conditions may remain effective after statehood.
- Congress may not, through admission conditions, deprive a state of powers essential to statehood and equality, particularly those concerning internal political organization and local self-government.
- A state’s assent to admission conditions cannot validate a federal restriction that the Constitution does not permit Congress to impose on an equal state.

## Conclusion

The Court held that Congress could not enforce an enabling-act restriction delaying Oklahoma’s ability to move its capital because selecting and changing the seat of government is an internal attribute of state sovereignty protected by the equal footing doctrine.


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