Hughes v. Oklahoma

Hughes v. Oklahoma, 441 U.S. 322 (1979), was a United States Supreme Court decision, which held that the United States Congress may enact legislation governing wildlife on federal lands.

Hughes v. Oklahoma
Supreme Court of the United States
Argued January 9, 1979 Decided April 24, 1979
Full case name	William Hughes v. Oklahoma
Citations	441 U.S. 322 (more) 99 S. Ct. 1727; 60 L. Ed. 2d 250; 1979 U.S. LEXIS 35
Case history
Prior	Appeal from the Court of Criminal Appeals of Oklahoma
Holding
The Congress may enact legislation governing wildlife on federal lands. When conflicting state law exists, the supremacy clause ensures that federal legislation will prevail.
Court membership
Chief Justice Warren E. Burger Associate Justices William J. Brennan Jr. · Potter Stewart Byron White · Thurgood Marshall Harry Blackmun · Lewis F. Powell Jr. William Rehnquist · John P. Stevens
Case opinions
Majority	Brennan, joined by Stewart, White, Marshall, Blackmun, Powell, Stevens
Dissent	Rehnquist, joined by Burger
This case overturned a previous ruling or rulings
Geer v. Connecticut (1896)

Background

Oklahoma enacted statutes that prevented any person from selling minnows found within the natural waters of the state of Oklahoma outside of the state of Oklahoma. Oklahoma claimed that the purpose of the statute was for wildlife conservation. The underlying legal controversy arose when William Hughes was convicted of shipping minnows fished from Oklahoma waters out of the state.

Opinion of the Court

The Supreme Court held that the statute violated the Dormant Commerce Clause because it discriminated the flow of interstate commerce without being the least discriminatory alternative. The Court stated that when conflicting state law exists, the supremacy clause ensures that federal legislation will prevail. The Court thereby overruled Geer v. Connecticut (1896), rejecting the earlier case's "19th century legal fiction of state ownership" of wildlife. In the Court's view, this "fiction" had "been eroded to the point of virtual extinction in cases involving regulation of wild animals." With the fall of Geer, the last precedential impediment to the federal government's wildlife management authority was removed.

See also

• List of United States Supreme Court cases, volume 441

Further reading

• Axline, M. D. (1981). "The End of a Wildlife Era: Hughes v. Oklahoma". Oregon Law Review. 60: 413.
• Hellerstein, Walter (1979). "Hughes v. Oklahoma: The Court, the Commerce Clause, and State Control of Natural Resources". The Supreme Court Review. 1979: 51–93. doi:10.1086/scr.1979.3109566. JSTOR 3109566.
• Matthews, Olen Paul (1986). "Who Owns Wildlife?". Wildlife Society Bulletin. 14 (4): 459–465. JSTOR 3782288.

External links

• Text of Hughes v. Oklahoma, 441 U.S. 322 (1979) is available from: CourtListener Findlaw Google Scholar Justia Library of Congress Oyez (oral argument audio)