Patsone v. Pennsylvania

Background

An Italian immigrant who had not become a U.S. citizen and who lived in Pennsylvania was charged and convicted for possessing a shotgun under a 1909 Pennsylvania law. The law made it illegal for resident noncitizens to kill wild birds or animals except in self‑defense and barred them from owning or possessing shotguns and rifles. The statute punished violations with a $25 fine and forfeiture of the gun. The man's conviction was affirmed in the state courts, and he appealed to the Supreme Court claiming violations of the Fourteenth Amendment and a treaty with Italy.

Reasoning

The Court considered whether the State could single out resident noncitizens to prevent destruction of wildlife and whether the treaty protected them. It said the property‑deprivation claim depended on whether the law unlawfully discriminated. The Court explained that preserving wild game is a legitimate state aim and that shotguns and rifles are especially linked to the banned activity. States may classify groups based on local experience, and the Court would not overturn the legislature's judgment here. Regarding the treaty, the Court held commerce and navigation protections did not apply and that treaty guarantees of security for persons and property did not prevent the State from limiting possession of hunting guns.

Real world impact

This ruling means Pennsylvania and similar States may enforce rules that bar resident noncitizens from owning hunting rifles or shotguns to protect wildlife. The decision allows fines and forfeiture when people violate such rules. The opinion left open that treaty protections might still apply to commercial uses of guns, but it affirmed the State’s power to preserve game for its citizens. The Chief Justice dissented, but the Court affirmed the conviction.