Kesler v. Dept. Of Public Safety (1961)
- Docket
- 14
- Decided
- 1961-01-01
- Category
- General
Summary
Question: Does Utah’s Motor Vehicle Safety Responsibility Act violate the Supremacy Clause of the Constitution by overriding the federal Bankruptcy Act? Conclusion: No. Justice Felix Frankfurter, writing for the Court held that Utah’s law did not violate the Supremacy Clause. First, Justice Frankfurter noted that the states had compelling interests in promoting highway safety within their jurisdictions, citing to various measures taken to encourage safe driving throughout the United States. He also noted that most of these statutes did not allow drivers to discharge judgments against them for driving violations in bankruptcy. Justice Frankfurter held that, although the Bankruptcy Act relieved an individual’s obligations to pay certain debts, it did not remove the negative consequences that a state may place on those debts. To that end, a state may decide that, in order to promote safe driving, a judgment must be paid before an individual may regain driving privileges. Justice Potter Stewart concurred in part, but felt that the appeal was not properly before the Court. Chief Justice Earl Warren, in his dissenting opinion, argued that the initial three-judge panel at the District Court was improper and that the Supreme Court did not have jurisdiction to hear the case. Finally, Justice Hugo L. Black, in his dissenting opinion argued that Utah’s statute took away rights conferred to all United State’s citizens under the Bankruptcy Act and, therefore, violated the Supremacy Clause in the Constitution.