Edwards V. California - Factual Background

Factual Background

Edwards was a citizen of the United States and a Californian resident who, in December 1939, left his home in the city of Marysville for Spur, Texas, with the intent of picking up his brother-in-law, Frank Duncan, (a US citizen and resident of Texas) and returning home to California with the man. During the course of his trip, Edwards was made aware of the fact that Duncan was unemployed, having little money and few personal possessions. As such, Duncan was classified as an indigent individual under California state law, the transportation of which into the state was strictly prohibited. Section 2615 of the Welfare and Institutions Code of California declares, “Every person, firm or corporation, or officer or agent thereof that brings or assists in bringing into the State any indigent person who is not a resident of the State, knowing him to be an indigent person, is guilty of a misdemeanor.” A complaint was subsequently filed against Edwards in Justice Court, where he was convicted and sentenced to six months imprisonment in the county jail. Edwards appealed to the Superior Court of Yuba County, and later to the Supreme Court of the United States on the argument that his sentence was unconstitutional on the basis that the California law violated the Interstate Commerce Clause.