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Coyle v. Smith

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Significance: The Supreme Court, citing the equality of states, ruled that Congress could not impose conditions on a territory that remained valid after it had become a state.


When Congress passed legislation admitting Oklahoma as a state, it stipulated that Guthrie was to be the capital until 1913. Oklahoma accepted this provision when it became a state in 1907, but after three years, it decided to move the capital to Oklahoma City. Some citizens asked the Supreme Court to decide if Congress could impose conditions that remained valid after admission. After examining cases relating back to the Northwest Ordinance of 1787, the Court, by a vote of 7-2, found that congressional restrictions were an impermissible infringement that made Oklahoma unequal with other states. Justice Horace H. Lurton, writing for the majority, stated that although the Constitution did not explicitly deal with this issue, the Court viewed state equality as an unwritten tradition.