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Edwards v. California

United States Supreme Court
314 U.S. 160 (1941)


Edwards (defendant) was a California resident. Edwards’s brother-in-law, Frank Duncan, lived in Texas. In December 1939, Edwards went to Texas to get Duncan and drive Duncan back to California in Edwards’s car. When Edwards arrived in Texas, he learned that Duncan was an indigent, or poor, person. Edwards and Duncan left Texas on January 1, 1940, to return to California. After Edwards and Duncan arrived in California, Duncan lived with Edwards for 10 days and then obtained financial aid from the Farm Security Administration. The State of California (plaintiff) filed a criminal complaint against Edwards under a state statute that made it a misdemeanor for anyone to knowingly bring into the state an indigent person who was not a California resident. Edwards objected to the complaint, arguing that the statute was unconstitutional. The justice court overruled Edwards’s objection, and the case went to trial. Edwards was convicted and sentenced to six months imprisonment. The superior court affirmed Edwards’s conviction, concluding that the statute was a valid exercise of the state’s police power. Edwards subsequently appealed to the United States Supreme Court.

Rule of Law


Holding and Reasoning (Byrnes, J.)

Concurrence (Jackson, J.)

Concurrence (Douglas, J.)

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