United States v. Wheeler

Background

The case involved the federal government seeking review of a lower court’s decision that threw out an indictment against 25 people. The indictment accused them of conspiring to seize and forcibly transport hundreds of named Arizona residents to New Mexico, armed and under threat of death, and of depriving those people of the right to live peacefully in Arizona and be free from unlawful removal.

Reasoning

The central question was whether the Constitution gives the United States power to criminally punish private people for blocking another person’s right to live and move within a State. The Court said no. It explained that the right to reside and travel was historically protected by the States and that the Constitution’s clauses about privileges among states prevent discriminatory state laws but do not give a general federal power to police private wrongs. The opinion relied on older decisions that treated these residence and movement rights as within state authority, except where federal functions or state action are directly involved.

Real world impact

As a result, similar private crimes of seizing and removing residents between states are not, under this opinion, matters the federal government can criminally prosecute; states must enforce their own laws. The Court noted narrow exceptions where federal interests or state action are directly affected, but in this case the federal indictment was properly quashed and that judgment was affirmed.

Dissents or concurrances

Justice Clarke dissented from the judgment, but the majority opinion alone controls the holding affirmed here.