Facts of the Case

At the height of the Great Depression, anyone who knowingly assisted a pauper in entering the state of California was guilty of a misdemeanor. A Californian named Edwards drove to Texas and then returned to California with his indigent brother-in-law. Edwards was found guilty of violating the state's "Okie law;" he was given a six-month suspended jail sentence.

Question

Does the Calfornia law violate the Constitution's Commerce Clause?

Conclusion

Yes, the Commerce Clause forbids a state to exclude indigents. California's interest in the health of its citizens and the sufficiency of its welfare funds do not justify the burden on interstate commerce occasioned by the law. Byrnes's unanimous opinion observed that "the indigent non-residents who are the real victims of this statute are deprived of the opportunity to exert political pressure upon the California legislature in order to obtain a change in policy." (See Mayor of New York v. Miln.)