Hines v. Davidowitz
312 U.S. 52 · Supreme Court of the United States · 1941
Facts
The Commonwealth of Pennsylvania enacted an Alien Registration Act in 1939, requiring every alien 18 years or over, with certain exceptions, to register annually. The Act mandated providing information, paying a $1 annual fee, receiving and carrying an identification card at all times, and exhibiting it upon demand by police or Department of Labor and Industry agents. Failure to register carried a fine of up to $100 or 60 days imprisonment, or both, while failure to carry or show the card resulted in a fine of up to $10 or 10 days imprisonment, or both. The Department of Labor and Industry was tasked with classifying registrations and furnishing copies to the Pennsylvania Motor Police.
Procedural history
A three-judge District Court enjoined enforcement of the Pennsylvania Alien Registration Act, ruling that it denied aliens equal protection and encroached upon federal legislative powers. An alien and a naturalized citizen initiated proceedings against state officials to enjoin the Act's enforcement. The District Court denied relief for the naturalized citizen but granted it for the alien, and the case reached the Supreme Court on appeal.
Issue
The central legal question is whether the Pennsylvania Alien Registration Act is valid, specifically whether it is preempted by the subsequently enacted federal Alien Registration Act of 1940. The Court must determine if Congress, by its federal act, foreclosed enforcement of Pennsylvania’s registration law, considering the respective powers of state and national governments in regulating aliens.
Holding
The Court affirmed the lower court's judgment, holding that the Pennsylvania Alien Registration Act is invalid and cannot be enforced. The federal Alien Registration Act preempts the state law, as the state act stands as an obstacle to the full purposes and objectives of Congress.
Rule
When the national government establishes comprehensive rules and regulations concerning aliens, such federal law is supreme and preempts state laws on the same subject. The Court's primary function is to determine if a state law stands as an obstacle to the accomplishment and execution of the full purposes and objectives of Congress, especially in fields affecting international relations. The power to regulate and register aliens is not a concurrent power of state and nation, but rather a subordinate state power to supreme national law. Congress, by enacting a complete and integrated system for alien registration, intended to protect the personal liberties of law-abiding aliens through a uniform national system, free from potentially inquisitorial state practices.
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