Facts
- The United States entered a 1916 treaty with Great Britain (for Canada) to protect migratory birds through conservation measures such as closed seasons.
- Congress enacted the Migratory Bird Treaty Act of 1918 and authorized federal regulations to implement the treaty.
- Missouri claimed primary authority over wild game within its borders and argued the federal regime violated the Tenth Amendment.
- Missouri filed a bill in equity in federal district court seeking to enjoin a U.S. game warden from enforcing the Act and its regulations.
- The district court dismissed the suit and upheld the Act’s constitutionality; Missouri appealed directly to the Supreme Court.
Issues
- Whether the 1916 migratory bird treaty was within the Article II treaty power.
- Whether the Migratory Bird Treaty Act of 1918 was a valid exercise of congressional power as necessary and proper to implement the treaty.
- Whether the treaty and implementing statute impermissibly infringed state sovereignty under the Tenth Amendment.
Decision
- The Supreme Court affirmed the dismissal and upheld the treaty and the Migratory Bird Treaty Act.
- The Court held Missouri had a sufficient quasi-sovereign interest in regulating game to seek injunctive relief, but it lost on the merits.
- The Court held the treaty was within the federal treaty power.
- The Court held the Act was constitutional as necessary and proper to implement the treaty.
- The treaty and implementing statute, as supreme federal law, were not invalidated by Missouri’s Tenth Amendment objections and could displace contrary state claims of authority over wildlife.
Legal Principles
- Valid treaties made under the authority of the United States are supreme law and may preempt conflicting state law and state assertions of reserved powers.
- Congress may enact legislation under the Necessary and Proper Clause to carry a valid treaty into effect, even if Congress would otherwise lack independent enumerated authority over the subject absent the treaty.
- Generalized state-sovereignty objections under the Tenth Amendment do not, by themselves, negate an otherwise valid treaty and necessary-and-proper implementing legislation.
- A state may invoke a quasi-sovereign interest (such as regulating the taking of game) to challenge allegedly unconstitutional federal action, even without a direct pecuniary injury.
Conclusion
The Court upheld federal protection of migratory birds by sustaining both the treaty and its implementing statute, confirming that a valid treaty and necessary-and-proper legislation can bind the states and override conflicting state authority notwithstanding Tenth Amendment objections.