Chandler v. Wise
Headline: Court dismisses challenge to Kentucky’s late ratification of the Child Labor Amendment after the Governor mailed the official certification, finding no live dispute left for courts to decide.
Holding: The Court dismissed the case because after Kentucky’s Governor mailed formal certification of ratification to the Secretary of State there was no longer a controversy for courts to decide.
- Prevents courts from deciding challenges after a governor sends official certification.
- Makes it harder for citizens to stop a state’s formal ratification once certified.
- Limits late procedural challenges to amendment ratifications after certification is mailed.
Summary
Background
In January 1937 the Kentucky legislature passed a resolution saying it ratified the constitutional amendment proposed by Congress in 1924, known as the Child Labor Amendment. A group of Kentucky citizens, taxpayers, and voters sued in state court to stop the Governor and legislative officers from sending certified copies of that resolution to the U.S. Secretary of State and congressional officers, and asked the court to declare the ratification invalid. The plaintiffs said the amendment had been rejected in 1926 and that Kentucky could not legally reconsider or had acted too late. A restraining order issued, but before the Governor was served he mailed a certified copy of the resolution to the Secretary of State.
Reasoning
The main question was whether courts could continue to decide the dispute after the Governor sent the official certification. The Supreme Court said that while the state court had initial power to hear the case, once the Governor forwarded the certification there was no longer a controversy that a court could resolve. For that reason the Supreme Court dismissed the review of the state-court rulings rather than deciding whether the ratification itself was valid.
Real world impact
The ruling means challengers lose a path to stop a state’s ratification after the Governor has sent official certification, because the Court found no live dispute remains for judicial resolution. The decision does not rule on the merits of whether Kentucky’s ratification followed constitutional procedures; it only ends this particular court fight once certification was mailed.
Dissents or concurrances
Two Justices (Black and Douglas) wrote separately to say courts generally lack power to interfere with the amendment process and therefore joined the dismissal; two others (McReynolds and Butler) would have affirmed the state-court decision on other grounds.
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