Hines v. Davidowitz
Encyclopedia
Hines v. Davidowitz, is a case applying the law of conflict preemption. The United States Supreme Court held that a state system of alien registration was superseded by a federal system (the Alien Registration Act) because it was an "obstacle to accomplishment" of its goals.
Justice Hugo L. Black emphasized the supremacy of federal power over this area of law:
In his dissent, Justice Stone noted the absence of any conflict between state and federal laws or any express congressional prohibition of state regulation.
Background
Pennsylvania passed a statute requiring aliens to register with the state, carry a state-issued identification card, and pay a small registration fee. The next year, Congress enacted a law requiring alien registration, but it did not require aliens to carry an identification card. The plaintiff conceded that there was neither explicit preemption, nor conflict preemption.Opinion of the Court
The Court applied the prong of preemption doctrine under which inquires whether "under the circumstances of [the] particular case, [state] law stands as an obstacle to the accomplishment and execution of the full purposes and objectives of Congress." Under the preemption doctrine, enforcement of a state alien registration law was barred by the federal Alien Registration Act.Justice Hugo L. Black emphasized the supremacy of federal power over this area of law:
In his dissent, Justice Stone noted the absence of any conflict between state and federal laws or any express congressional prohibition of state regulation.