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Coyle v. Smith
Coyle v. Smith, 221 U.S. 559 (1911), was a Supreme Court of the United States case that held that the newly created state of Oklahoma was permitted to move its capital city from Guthrie to Oklahoma City, notwithstanding the Enabling Act provision that prohibited it from being moved from Guthrie until after 1913. BackgroundIn 1907, Oklahoma was admitted as a U.S. state. The new state's capital was located in Guthrie. Section 497 of the Oklahoma Constitution stated that the terms of the U.S. Congress's enabling act of 1906—which allowed Oklahoma to create a state constitution and be admitted to the Union—were "accepted by ordinance irrevocable". Section 2 of the enabling act read:
On December 29, 1910, the state of Oklahoma enacted a statute which removed the state capital from Guthrie to Oklahoma City. W.H. Coyle, owner of large property interests in Guthrie, sued the state of Oklahoma, arguing that the move was performed in violation of the state constitution's acceptance of the terms of Congress's enabling act. HoldingThe Supreme Court held that preventing the state of Oklahoma the right to locate its own seat of government deprived it of powers which all other states of the Union enjoyed, and thus violated the traditional constitutional principle that all new states be admitted "on an equal footing with the original states". As a result, the provision of the enabling act which temporarily restricted Oklahoma's right to determine where its seat of government was no longer valid after Oklahoma was actually admitted. As stated by Justice Lurton:
Quoting Chief Justice Chase's opinions regarding the indestructibility of the Union and the principle of federalism contained in Texas v. White and Lane County v. Oregon, the opinion concludes:
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