Trial Court's Power: State Law Unconstitutionality

The concept of a state trial court declaring a state law unconstitutional is a complex one, with a variety of outcomes depending on the specific circumstances and the laws in question. State laws can be deemed unconstitutional if they violate the US Constitution, with the Supreme Court playing a crucial role in interpreting federal law and ensuring it takes precedence over conflicting state laws. This is based on the Supremacy Clause, which mandates that the Constitution, laws, and treaties of the US take precedence over state laws. State courts are bound to uphold federal law and disregard state law in the event of a conflict. This has resulted in state laws being challenged on grounds such as deprivation of property without due process, violation of the Equal Protection Clause, and imposition of unreasonable conditions.

State laws that violate the Due Process Clause

The Due Process Clause, as outlined in the Fourteenth Amendment, states that no state may deprive any person of "life, liberty, or property, without due process of law". This clause is a legal obligation for all states, ensuring that all levels of government operate within the law and provide fair procedures.

• Impose unreasonably low intrastate freight rates, amounting to a deprivation of property without due process, as in the case of Houston & Texas Cent. Ry. v. Texas, 170 U. S. 243 (1898).
• Declare an individual presumptively guilty of a crime, such as a Louisiana law that established a rebuttable presumption of involvement in a monopoly or conspiracy for those purchasing sugar below a certain price. This law violated both the Due Process and Equal Protection Clauses of the Fourteenth Amendment.
• Impose unreasonable conditions on foreign corporations, such as a Wisconsin law that revoked the license of any foreign corporation that removed to a federal court, which was deemed an unconstitutional condition.
• Do not provide fair procedures for students who are thought to have violated school rules, such as expulsion for misbehaviour, which must be preceded by due process, i.e., fair procedures.
• Discriminate against foreign corporations in favour of local commerce, as the modern "negative" commerce clause constrains states' authority to do so.
• Interfere with the right to conduct business, such as statutes imposing terms on businesses entering into agreements, which fall within the state's competency and do not violate due process.
• Do not adequately prevent fraud, such as state regulations requiring the disclosure of product nature to prevent fraud and protect consumers, which do not violate the Due Process Clause.

State laws that violate the Equal Protection Clause

One of the earliest applications of the Equal Protection Clause was in Nixon v. Herndon (1927), where the Supreme Court ruled that the Fourteenth Amendment prohibited the denial of the vote based on race. In Baker v. Carr (1962), the Court found that malapportionment of districts in Tennessee violated the Equal Protection Clause, as some legislators represented far more residents than others.

In the context of education, the Supreme Court has used the Clause to address racial discrimination in school admissions. In Missouri ex rel. Gaines v. Canada (1938), the Court held that a State offering legal education to whites but not to blacks violated the Equal Protection Clause. The companion cases of Sweatt v. Painter and McLaurin v. Oklahoma State Regents, both decided in 1950, paved the way for school integration.

The Supreme Court has also applied the Equal Protection Clause to marriage laws. In Loving v. Virginia (1967), the Court held that laws prohibiting interracial marriages violated the Clause. More recently, in Obergefell v. Hodges (2015), the Court suggested that state laws distinguishing between same-sex and opposite-sex marriages violated the Equal Protection Clause, indicating that discrimination against gays and lesbians may violate the Clause.

Additionally, the Supreme Court has considered the application of the Equal Protection Clause to governmental policies that unintentionally lead to racial disparities. In Arlington Heights v. Metropolitan Housing Corp. (1977), the Court addressed a case where a city's refusal to re-zone land for low-income, racially integrated housing resulted in a racially disparate impact. However, the Court decided that the Equal Protection Clause does not forbid such policies, although Congress may have the power to address unintentional disparate impacts under other constitutional clauses.

While the Equal Protection Clause was originally intended to protect African Americans from discrimination, its broad wording has led the Supreme Court to interpret it as prohibiting all racial discrimination, including against whites, Hispanics, Asians, and Native Americans. This has sparked ongoing debates about whether it is unconstitutional for governments to consider race as a positive factor in university admissions, employment, and government contracting.

State laws that are preempted by federal law

The US Constitution declares that federal law is "the supreme law of the land". When federal and state laws conflict, federal law displaces or preempts state law, due to the Supremacy Clause of the Constitution. This is known as the preemption doctrine, which refers to the idea that a higher authority of law will displace the law of a lower authority when the two conflict.

There are three types of conflicts regarding preemption:

• Outright conflict: When a state law directly opposes a federal law.
• Express preemption: When a state law directly opposes federal authority in a particular area.
• Implied preemption: This occurs when one of three things happen: when a state law prohibits an act permitted by federal law, when a state law permits an act prohibited by federal law, or when there is clear legislative intent that the "field" is preempted by federal law.

Examples of state laws that are preempted by federal law include:

• A Washington law that established a quarantine against the importation of hay and alfalfa meal from areas harbouring the alfalfa weevil was inoperative due to federal legislation.
• A Georgia law requiring cab curtains and automatic firebox doors in locomotives was preempted by the Federal Boiler Inspection Act.
• An Arkansas law that prohibited carriers from exempting themselves from liability for lost shipments was preempted by Congress's own legislation.
• A Texas property tax on bank shares, computed on the basis of a bank's net assets without any deduction for the value of US obligations held by the bank, was invalid as it conflicted with federal law.
• A Virginia statute creating a cause of action for "insulting words" as construed to permit recovery for use in a labour dispute was preempted by federal labour law.
• A New Mexico law providing for the roundup and sale of unbranded and unclaimed horses and burros on public lands of the US was held inoperative as these animals were protected by federal law.
• A Nebraska statute setting intrastate freight rates was held to impose rates so low as to amount to a deprivation of property without due process of law.

State laws that conflict with federal statutes or treaties

In the United States, federal laws are the highest authority, but states also have their own laws. The Supremacy Clause, found in Article VI of the US Constitution, establishes that the Constitution, federal laws made pursuant to it, and treaties made under its authority, constitute the "supreme Law of the Land", and thus take priority over any conflicting state laws. This means that federal laws always prevail over state laws.

The Supremacy Clause was first applied in the 1796 case, Ware v. Hylton, where the Court ruled that a treaty superseded conflicting state law. The Court held that states and private citizens were bound to comply with the federal government's treaty obligations, which was, in turn, bound by the "law of nations" to honour treaties.

The Supremacy Clause has been interpreted to mean that the Constitution binds the judges in every state, notwithstanding any state laws to the contrary. This means that state courts are bound by, and state constitutions subordinate to, the supreme law. However, federal statutes and treaties must be within the parameters of the Constitution; they must be pursuant to the federal government's enumerated powers and not violate other constitutional limits on federal power, such as the Bill of Rights.

There have been many instances where state and federal laws have conflicted. For example, same-sex marriage and marijuana use are two examples of laws that differ between states and the federal government. While some states have legalised marijuana for recreational or medical purposes, it is still illegal under federal law. Similarly, while same-sex marriage is legal in many states, it is not legal in all of them. In 2013, California voters passed a law banning same-sex marriage, but the federal government overturned this law as illegal.

State court's duty to grant relief that federal law requires

State courts have a duty to enforce federal law and grant relief when required by federal law. This is known as the Supremacy Clause, which states that federal law is the "supreme law of the land".

In the 1876 case of Claflin v. Houseman, the Supreme Court ruled that state courts could hear cases arising under federal bankruptcy law. The Court held that the laws of the United States are binding on state courts and citizens, and that the United States is a "paramount sovereignty". This means that state courts have concurrent jurisdiction with federal courts in certain cases.

However, federal law can grant exclusive jurisdiction to federal courts in certain matters, such as bankruptcy cases under 28 U.S.C. § 1334. In such cases, state courts would not have the power to grant relief under federal law.

In the 2009 case of Haywood v. Drown, the Supreme Court considered a New York state statute that attempted to divest New York state courts of jurisdiction over suits seeking money damages from corrections officers. The Court held that the New York law violated the Supremacy Clause, as only a neutral jurisdictional rule can be deemed a "valid excuse" for a state court to refuse to hear a federal claim.

Therefore, state courts have a duty to grant relief that federal law requires, unless Congress gives federal courts exclusive jurisdiction over a particular matter.

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