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In the years leading up to 1916, Congress attempted to pass legislation for the protection of migratory birds. But that attempt was thwarted when a federal court struck down the statute as beyond Congress’s constitutional authority under the Commerce Clause.
Shortly after, in 1916, President Woodrow Wilson entered a treaty for the protection of migratory birds with Great Britain. Congress then passed the Migratory Bird Treaty Act of 1918—which barred anyone from killing, capturing, or selling protected migratory birds—to give effect to the treaty.
The State of Missouri sued, arguing that the treaty and statute violated states’ rights under the Tenth Amendment. According to Missouri, those rights included total control of wild game and birds within state borders.
The case of Missouri v. Holland, 252 U.S. 416 (1920), ultimately came before the United States Supreme Court. The issue was whether Congress could pass a law that would otherwise be outside Congress’s constitutional authority, if the law was meant to give effect to a valid treaty.
A majority of the Court held that both the treaty and the statute were valid. The president and Congress followed the procedures set forth in the Constitution to validly enact the treaty. Thus, the treaty was the supreme law of the land, and Congress had the power to pass any law necessary and proper to give it effect.
Though controversial, Missouri v. Holland was a landmark case for its expansive view of congressional authority with respect to legislation giving effect to valid treaties.