Case Brief: Missouri v. Holland

 Missouri (Plaintiff) v. Holland (Defendant)

252 U.S. 416 (1920)

Fact:

On December 8, 1916, a treaty between the United States and Great Britain was proclaimed by the president for protecting several species of birds in their annual migrations traversed parts of the U.S. and of Canada. The Migratory Bird Treaty Act enacted into effect in 1918 and prohibited killing, capturing or selling migratory birds.

Missouri State brought a bill to prevent a game warden of United States (Holland) from attempting to enforce the Act in 1918 and the regulations made by Secretary of Agriculture in pursuance of the same.

Missouri contended that the statute was an unconstitutional interference with the reserved rights of the States and an invasion of the sovereign rights of the State. The State also argued that the State owned the exclusive right of migratory birds in their sovereign capacity for the benefit of their people, and that control could not be displaced by Congress.

The District Court sustained to dismiss a motion by holding that the Act was constitutional. The State of Missouri appealed.

Issues:
       Whether the treaty and statute are void as an interference with the rights reserved to the States?

Holding:

       Yes. The treaty and statute upheld.

Reasoning:

        Article II, sec. 2 of Constitution provides that the President has the power to make treaties is delegated expressly, and the treaties-making under the authority of the United States are declared the supreme law of the land. If the treaty is valid then there is no dispute about the validity of the statute under Article I, sec. 8 of Constitution, as a necessary and proper means for Congress to enact legislation to comply the treaty.

The claim of State upon title of migratory is not stronger than the authority a treaty is enforced under the Constitution. In this case, the migratory birds have no permanent habitat within the same territory. Besides, there is no state could deal with this problem and provide adequate regulations alone. Therefore, it is necessary to take joint action under international law. Furthermore, there is a great interest for national to protect migratory birds because they are a food supply and the protectors of forests and crops. This shows that the Tenth Amendment is irrelevant here because the power to make treaties is delegated expressly. As a result, the Treaty and statute do not violate the rights reserved to the States, unless the statute is unconstitutional.

Conclusion:

         Judgment confirmed.