Missouri v. Holland, 252 U.S. 416 (1920)

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

  1. Whether the 1916 migratory bird treaty was within the Article II treaty power.
  2. Whether the Migratory Bird Treaty Act of 1918 was a valid exercise of congressional power as necessary and proper to implement the treaty.
  3. 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.
  • 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.