Hines v. Davidowitz

Background

Pennsylvania passed a 1939 law requiring most noncitizens 18 or older to register each year, pay $1, receive and carry an identification card, show it on demand, and face fines or jail for noncompliance. A three-judge federal court enjoined enforcement after a noncitizen challenged the law. While that appeal was pending, Congress enacted a 1940 federal Alien Registration Act creating a single national registration system.

Reasoning

The Court’s central question was whether the federal law precluded the state law. The majority said yes: regulation of aliens touches foreign affairs, an area where national authority is supreme, and Congress had adopted a comprehensive, uniform registration scheme. The federal law required a single registration, fingerprinting, secrecy of files, and punished only willful failures, and did not require carrying identification cards. Because the federal statute set the national standard, Pennsylvania’s additional and different requirements conflicted with Congress’s purpose and could not be enforced.

Real world impact

The ruling prevents Pennsylvania from enforcing its separate alien registration system and limits states from imposing their own ID-and-carry or annual-registration requirements that conflict with the federal design. Aliens in states with similar laws are affected because the decision gives the federal system priority over inconsistent state measures.

Dissents or concurrances

A dissent argued that Congress had not plainly intended to exclude state regulation and that states retain police powers to register resident noncitizens unless a direct conflict exists; the dissent would have reversed the injunction.