Brief Fact Summary. The Arkansas State Constitution contained an amendment limiting the number of terms federal Congressional and Senatorial candidates from Arkansas could serve. The Arkansas Supreme Court held that the amendment was unconstitutional.
Synopsis of Rule of Law. The Tenth Amendment of the United States Constitution (Constitution) does not reserve rights for the States that were not within the original powers of the States.
Issue. Can individual states add additional requirements for election to Congress other than those found in the Constitution?
Held. No. Judgment affirmed.
Arkansas claimed the Tenth Amendment and the principle of reserved powers allow the States to add qualifications that Congressional candidates elected within the State must meet.
The Supreme Court found that the power to add such qualifications was not within the “original powers” of the States because no such right existed before the enactment of the Constitution. Therefore, the Tenth Amendment did not reserve this right for the States. Additionally, the Supreme Court found that the Framers intended the Constitution to be the sole source of qualifications for members of Congress, thereby divesting the States of any power to add qualifications.
Arkansas also argued that the amendment is not a qualification, but rather an acceptable use of the State’s power to regulate the “Times, Places, and Manner of Holding Elections” under Article I. The Supreme Court found this Article only allowed the States to create procedural regulations, not to exclude classes of candidates.
The States have no power, by taxation or otherwise, to retard, impede, burden, or in any manner control, the operations of the constitutional laws enacted by Congress to carry into execution the powers vested in the general government.View Full Point of Law