Pennsylvania v. West Virginia
Headline: West Virginia’s 1919 law struck down for violating limits on interstate commerce, freeing Pennsylvania and Ohio from its restrictions and barring West Virginia officials from enforcing it.
Holding: The Act passed by West Virginia on February 10, 1919 (Chapter 71) is void because it violates the Constitution’s limits on interstate commerce, and West Virginia officials are enjoined from enforcing it.
- Bars West Virginia officials from enforcing the 1919 law.
- Returns disputes over interstate commerce to federal constitutional limits.
- Splits litigation costs: West Virginia pays half; Pennsylvania and Ohio one-fourth each.
Summary
Background
The States of Pennsylvania and Ohio brought suits against the State of West Virginia challenging a law enacted February 10, 1919 (Chapter 71 of the West Virginia Acts of 1919). The cases were submitted on the written pleadings and the evidence, and the Court entered a decree on June 11, 1923. The suits asked the Court to decide whether the West Virginia statute could stand given the Constitution’s rules about commerce between the States.
Reasoning
The core question was whether the West Virginia law conflicted with the Constitution’s limitations on state action in matters of interstate commerce. The Court concluded that the 1919 Act was void and inoperative because it contravened those constitutional limits. As a result, the Court enjoined West Virginia and its officers, agents, and servants from enforcing or attempting to enforce the statute.
Real world impact
The decree prevents West Virginia officials from applying the 1919 law and resolves this dispute in favor of Pennsylvania and Ohio on the specific constitutional ground stated. The Court also apportioned the aggregate costs: West Virginia to pay one-half, Pennsylvania one-fourth, and Ohio one-fourth. The Court ordered payment of $6,000 to the commissioner who took the evidence, taxed as part of the costs and payable in the same proportions, and directed the Clerk to send authenticated copies of the decree to the chief magistrates of the three States.
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