EDWARDS v. CALIFORNIA 314 U.S. 160 (1941)

The years of the Great Depression were especially harsh for residents of the Dust Bowl. Many migrated to the West, and particularly California, in conditions of poverty graphically detailed in John Steinbeck's novel, The Grapes of Wrath (1939). California's hospitality to this "huge influx of migrants" was reflected in its "Okie law," making it a misdemeanor knowingly to assist an indigent person in entering the state. Edwards, a Californian, went to Texas and drove his indigent brother-in-law back to California. For his troubles, he was given a six-month suspended jail sentence for violating the Okie law.

The Supreme Court unanimously reversed the conviction. Justice james f. byrnes, for the Court, concluded that the law violated the commerce clause. The state's concerns with health and the integrity of its welfare funds were insufficient to justify so severe a burden on interstate commerce. Justice william o. douglas, concurring, would have rested decision on the privileges and immunities clause of the fourteenth amendment. Interstate travel was a privilege of national citizenship, and to deny that privilege to indigents would create an inferior class of citizens. Justices hugo l. black and frank murphy joined this opinion.

Justice robert h. jackson, concurring, agreed with Justice Douglas but also remarked that indigence was "a neutral fact—constitutionally an irrelevance, like race, creed, or color."

Kenneth L. Karst
(1986)

(see also: Equal Protection of the Laws; Wealth Discrimination.)