State of Missouri v. Holland (1900)
- Docket
- 609
- Decided
- 1900-1940-
Summary
Question: Did the treaty infringe upon rights reserved to the states by the Tenth Amendment? Conclusion: In a 7-to-2 decision authored by Justice Oliver Wendell Holmes, the Court upheld the exercise of the treaty power and found no violation of the Tenth Amendment. The Court reasoned that the national interest in protecting wildlife could be protected only by national action. The Court further reasoned that the Supremacy Clause (Article VI, Clause 2) renders treaties the “supreme law of the land,” a finding that trumps any state-level concerns with regard to the provisions of any treaty. The Supremacy Clause further implied that the treaty provisions were not subject to questioning by the states under the process of judicial review.