Coyle v. Smith

The state Constitution authorized the Governor to convene the Legislature at another location when public safety, welfare, or the members' safety or health required it, subject to later concurrence by two-thirds of each house. The Court rejected the argument that the Legislature first had to assemble in Guthrie merely to approve moving to Oklahoma City.

The constitutional provision was designed for emergencies, such as war, insurrection, or epidemic, in which requiring an initial meeting at the ordinary seat of government could be impracticable or impossible. Because each house approved the call after assembling at Oklahoma City, the constitutional condition was met.

Whether the circumstances justified the Governor's emergency judgment was a political question. Once the Governor and Legislature acted within the constitutional process, the Court would not review that judgment.

The Constitution fixed the expiration of the first House members' and short-term senators' terms at the fifteenth day after the 1908 regular state election. Their successors, once elected and qualified, were entitled to sit, preventing an interregnum in legislative government.

The Court rejected the claim that a territorial holdover statute extended the first legislators' terms to January 1, 1909. The constitutional provisions governing the new state Legislature covered the same subject and displaced the earlier territorial statute.

Both legislative houses had determined their own memberships, and the executive branch accepted that determination. In a doubtful matter involving the political organization of a coordinate branch, that practical construction strongly supported the Court's conclusion.

A law is not special or local merely because it operates at a particular geographic place. The question is whether it concerns only a particular locality or instead addresses a public matter in which the entire state has an interest.

The location of the state capital concerns every citizen and the functioning of statewide government. Treating the act as local would also improperly cast ordinary statewide measures—such as statutes concerning the Governor's salary, the Supreme Court's terms, or state institutions—as special legislation.

The act's provisions establishing capital commissioners and authorizing the acceptance of property or donations were reasonably related to locating and establishing a capital. They were means of carrying out the principal subject rather than separate and unrelated subjects.

The Court applied a practical construction of the title requirement. Measures necessary to acquire, prepare, and administer the capital site were cognate to the stated purpose of permanently locating the seat of government.

The Court followed its enrolled-bill rule. When a bill is signed by the presiding officers of both houses after public reading, approved by the Governor, and deposited with the Secretary of State, the courts will not consult the legislative journals to show that constitutional passage procedures were not followed.

Because the challenged act bore the required legislative and executive authentication, the alleged failure to read it on three separate days was not a basis for judicial invalidation.

A state enters the Union on an equal footing with the original states and therefore acquires the ordinary powers of state sovereignty. The location of a state capital is an internal governmental matter, not an area of authority delegated to Congress by the federal Constitution.

The Court distinguished enforceable statehood conditions involving federal property, Indian affairs, interstate commerce, or other subjects within an enumerated federal power. Congress may protect federal proprietary interests or regulate matters within its continuing constitutional authority, but it cannot permanently dictate an admitted state's local governmental arrangements.

The Court relied on decisions holding that restrictions derived from territorial ordinances or enabling acts cease to limit a state after admission unless they are voluntarily preserved as state law. To hold otherwise would allow Congress to create states with unequal political powers.

The Convention's acceptance of the capital provision could not make the restriction irrevocable. At most, the acceptance operated as a temporary ordinance or legislative enactment; it was not a constitutional provision beyond legislative repeal.

The Court treated the nonbinding remainder of the Convention's capital ordinance as ordinary legislation rather than fundamental law. Unlike a constitutional provision, it had not been submitted to the people as part of the Constitution and did not establish an unamendable limitation on legislative authority.

The Convention itself had incorporated many Enabling Act provisions into the Constitution but omitted the temporary-capital provision. That choice indicated that the Convention did not intend the ordinance to have constitutional status.

Because the ordinance was legislative in character, the Legislature could repeal or supersede it. The power to establish or remove a seat of government is a governmental power that cannot be permanently surrendered by an earlier legislative act.