Coyle v. Smith
United States Supreme Court
221 U.S. 559 (1911)
Facts
On June 16, 1906, the United States Congress passed An Act to Enable the People of Oklahoma and the Indian Territory to Form a Constitution and State Government and be Admitted into the Union on Equal Footing with the Original States (the Enabling Act), which admitted the state of Oklahoma into the union. The Enabling Act provided that the capital of Oklahoma would remain at Guthrie until 1913 and then be decided by a state election. When ratified, the Oklahoma Constitution did not identify the location of the capital, but the convention framing the constitution adopted a separate ordinance accepting the Enabling Act as irrevocable. On December 29, 1910, the Oklahoma legislature passed the Oklahoma Act, which provided that the capital of the state would immediately be moved from Guthrie to Oklahoma City. Coyle (plaintiff) filed suit alleging that the Oklahoma Act violated the Enabling Act. The Oklahoma Supreme Court upheld the Oklahoma Act, and Coyle sought review by the United States Supreme Court.
Rule of Law
Issue
Holding and Reasoning (Lurton, J.)
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