Brief Fact Summary. A state alien registration law was challenged on the ground that the federal alien registration law occupied the field and therefore preempted the state law.
Synopsis of Rule of Law. If the federal government exercises superior authority in a particular field and enacts a complete system of regulation, states cannot enact laws which conflict/interfere/curtail or complement, the federal law, or even enforce additional or auxiliary regulations.
In 1939 Pennsylvania passed an Alien Registration Act (the state Act), which required aliens to register annually, provide information and carry a registration card to be shown to police, or they would be criminally prosecuted. The next year, the Federal Alien Registration Act (the Federal Act) provided for a single registration and they did not have to carry a registration card. The Appellees, Davidowitz and other aliens (Appellees), challenged the law as denying equal protection to aliens, and on other constitutional grounds. A federal district court enjoined the enforcement of the state Act.
Issue. If the Federal government has exercised superior authority in a particular field can the states enact laws which conflict or interfere with, curtail or complement, the federal law, or enforce additional or auxiliary regulation?
Held. No. The Supreme Court of the United States (Supreme Court) declares that Congress intended for federal government to occupy the field of immigration regulation and not the states.
Dissent. Points of Law - for Law School Success
To determine the boundaries that Congress sought to occupy within the field, we look to the federal statute itself, read in the light of its constitutional setting and its legislative history. View Full Point of Law
Justice Harlan Fiske Stone (J. Stone) did not think Congress made a complete and exclusive registration system for aliens. He felt that the Supreme Court cannot strike down a state law that was immediately concerned with social order and safety of its people. Discussion.
The federal government has the power over immigration, naturalization and deportation. When the federal government provides a complete standard for the registration of aliens, the states cannot conflict or interfere with, or enforce additional regulations. Congress wanted one uniform national system.