United States v. Wheeler (1920)
| United States v. Wheeler | |
|---|---|
|
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| Argued April 28, 1920 Decided December 13, 1920 |
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| Full case name | United States v. Wheeler, et al. |
| Citations | 254 U.S. 281 (more)
41 S. Ct. 133; 65 L. Ed. 270; 1920 U.S. LEXIS 1159
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| Prior history | Error to the District Court of the United States for the District of Arizona |
| Holding | |
| The Constitution grants to states, not the federal government, the power to prosecute individuals for wrongful interference with the right to travel. | |
| Court membership | |
| Case opinions | |
| Majority | White, joined by McKenna, Holmes, Day, Van Devanter, Pitney, McReynolds, Brandeis |
| Dissent | Clarke |
| Laws applied | |
| U.S. Const. art. IV, §2; §19 of the Criminal Code | |
United States v. Wheeler, 254 U.S. 281 (1920), is an 8-to-1 ruling by the Supreme Court of the United States that held that the Constitution alone did not grant the federal government the power to prosecute kidnappers, and only the states had the authority to punish a private citizen's unlawful violation of another's freedom of movement. The case was a landmark interpretation of the Privileges and Immunities Clause of the Constitution, and contained a classic legal statement of the right to travel which continues to undergird American jurisprudence.
On June 26, 1917, Local 800 of the Industrial Workers of the World (or IWW, a labor union), struck the Phelps Dodge Corporation and other mining companies in the town of Bisbee, Arizona. Nearly 3,000 miners (about 38% of the town's total population) walked out. The strike was a peaceful one. However, Walter S. Douglas, the president of Phelps Dodge, was determined to break the strike.
On July 11, Douglas and other Phelps Dodge corporate executives met with Cochise County Sheriff Harry Wheeler to conspire to seize, by force of arms, all the striking workers, forcibly transport (deport) them several hundred miles away from Bisbee, and abandon them in another desert town without food, clothing or funds. To this end, Sheriff Wheeler recruited and deputized 2,200 men from Bisbee and the nearby town of Douglas to act as a posse. Phelps Dodge officials also met with executives of the El Paso and Southwestern Railroad, who agreed to provide rail transportation for any deportees. Phelps Dodge and the other employers provided Sheriff Wheeler with a list of all the men on strike, as well as suspected IWW sympathizers.
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