Coyle v. Smith Case Brief

Facts of the Case

Petitioner citizens claimed that the Oklahoma Act, providing for the immediate location of the capital at Oklahoma City was void as repugnant to the Enabling Act of Congress of June 16, 1906, under which the State was admitted to the Union. Prior to the Oklahoma Act, the capital was located in another city. The citizens were owners of property interests in the former location of the capital. The state court rejected the citizens’ challenges under the state constitution. On review, the Court affirmed.


Does shackling a convicted offender during the penalty phase of a capital case violate the due process clauses of the Fifth and 14th Amendment?


Yes. This was congressional overreaching. States are on an equal footing to determine their own location for the seat of government.

Case Information

Citation: 221 US 559 (1911)
Argued: Apr 5 – 6, 1911
Decided: May 29, 1911
Case Brief: 1911