Zschernig v. Miller

E14280

U.S. Supreme Court case landmark foreign affairs case

Zschernig v. Miller is a 1968 U.S. Supreme Court case that limited state involvement in foreign affairs by striking down an Oregon law affecting inheritance rights of foreign nationals as an intrusion into the federal government's exclusive foreign relations power.

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All labels observed (2)

Label	Occurrences
Zschernig et al. v. Miller, Administrator	1
Zschernig v. Miller canonical	1

How this entity was disambiguated

This entity first appeared as the object of triple T125866 — resolving that mention is where its identity was fixed. The disambiguator weighed these candidate entities and picked the highlighted one (or “None”, minting a new entity). This is how homonymy is resolved: the same surface form can point to different entities.

NED1 Entity disambiguation (via context triple) gpt-5-mini-2025-08-07

Target entity: Zschernig v. Miller
Context triple: [Crosby v. National Foreign Trade Council, relatedCase, Zschernig v. Miller]

A. Sherbert v. Verner
Sherbert v. Verner is a landmark 1963 U.S. Supreme Court case that strengthened protections for religious liberty by requiring strict scrutiny of government actions that substantially burden individuals’ religious practices.
B. Bolling v. Sharpe
Bolling v. Sharpe is a 1954 U.S. Supreme Court case that held racial segregation in Washington, D.C. public schools unconstitutional under the Fifth Amendment’s Due Process Clause.
C. Briggs v. Elliott
Briggs v. Elliott was a landmark federal court case from South Carolina challenging racial segregation in public schools, and it became one of the key cases consolidated into Brown v. Board of Education.
D. Chiafalo v. Washington
Chiafalo v. Washington is a 2020 U.S. Supreme Court case that unanimously upheld states’ authority to penalize or replace “faithless electors” who do not vote in line with their state’s popular vote in presidential elections.
E. United States v. Comstock
United States v. Comstock is a 2010 U.S. Supreme Court case that upheld Congress’s authority to civilly commit mentally ill, sexually dangerous federal prisoners beyond their release date under the Constitution’s Necessary and Proper Clause.
F. None of above. chosen
G. Unsure - the case is ambiguous/there is not enough information to decide.

NED2 Entity disambiguation (via description) gpt-5-mini-2025-08-07

Target entity: Zschernig v. Miller
Target entity description: Zschernig v. Miller is a 1968 U.S. Supreme Court case that limited state involvement in foreign affairs by striking down an Oregon law affecting inheritance rights of foreign nationals as an intrusion into the federal government's exclusive foreign relations power.

A. Sherbert v. Verner
Sherbert v. Verner is a landmark 1963 U.S. Supreme Court case that strengthened protections for religious liberty by requiring strict scrutiny of government actions that substantially burden individuals’ religious practices.
B. Bolling v. Sharpe
Bolling v. Sharpe is a 1954 U.S. Supreme Court case that held racial segregation in Washington, D.C. public schools unconstitutional under the Fifth Amendment’s Due Process Clause.
C. Briggs v. Elliott
Briggs v. Elliott was a landmark federal court case from South Carolina challenging racial segregation in public schools, and it became one of the key cases consolidated into Brown v. Board of Education.
D. Chiafalo v. Washington
Chiafalo v. Washington is a 2020 U.S. Supreme Court case that unanimously upheld states’ authority to penalize or replace “faithless electors” who do not vote in line with their state’s popular vote in presidential elections.
E. United States v. Comstock
United States v. Comstock is a 2010 U.S. Supreme Court case that upheld Congress’s authority to civilly commit mentally ill, sexually dangerous federal prisoners beyond their release date under the Constitution’s Necessary and Proper Clause.
F. None of above. chosen

Statements (49)

Predicate	Object
instanceOf	U.S. Supreme Court case ⓘ landmark foreign affairs case ⓘ
areaOfLaw	constitutional law ⓘ federal courts ⓘ international law ⓘ
citation	19 L. Ed. 2d 683 ⓘ 389 U.S. 429 ⓘ 88 S. Ct. 664 ⓘ
concurrenceBy	Chief Justice Earl Warren ⓘ linked to: Earl Warren Justice Abe Fortas ⓘ linked to: Abe Fortas Justice Byron White ⓘ linked to: Byron R. White Justice Hugo L. Black ⓘ linked to: Hugo L. Black Justice John Marshall Harlan II ⓘ linked to: John M. Harlan II Justice Potter Stewart ⓘ linked to: Potter Stewart Justice Thurgood Marshall ⓘ linked to: Thurgood Marshall Justice William J. Brennan Jr. ⓘ linked to: William J. Brennan Jr.
constitutionalProvision	Article I of the U.S. Constitution ⓘ linked to: Article I of the United States Constitution Article II of the U.S. Constitution ⓘ linked to: Article II of the United States Constitution Supremacy Clause ⓘ
country	United States ⓘ linked to: United States of America
court	Supreme Court of the United States ⓘ
decisionDate	1968-01-15 ⓘ
effect	established that state laws cannot have more than incidental or indirect effect on foreign relations ⓘ restricted state involvement in foreign affairs ⓘ
factPattern	Oregon law conditioned inheritance by nonresident aliens on reciprocity and proof of rights in their home country ⓘ
fullName	Zschernig et al. v. Miller, Administrator ⓘ linked to: Zschernig v. Miller
holding	Oregon probate statute was unconstitutional as an intrusion into the federal government’s exclusive foreign relations power ⓘ state law was invalid under the Foreign Affairs power even without a conflicting federal statute or treaty ⓘ
jurisdiction	federal question jurisdiction ⓘ
keyDoctrine	dormant foreign affairs preemption ⓘ limits on state regulation with more than incidental effect on foreign relations ⓘ
legalIssue	constitutionality of state law affecting foreign nationals’ inheritance ⓘ scope of federal government’s exclusive power over foreign relations ⓘ
legalSubject	conflict of laws ⓘ federal preemption ⓘ foreign affairs power ⓘ inheritance rights ⓘ
lowerCourt	Supreme Court of Oregon ⓘ linked to: Oregon Supreme Court
lowerCourtDisposition	judgment of the Supreme Court of Oregon reversed ⓘ
majorityOpinionBy	Justice William O. Douglas ⓘ linked to: William O. Douglas
parties	foreign heirs who were residents of East Germany ⓘ
relatedCase	American Insurance Association v. Garamendi ⓘ linked to: American Insurance Assn. v. Garamendi Crosby v. National Foreign Trade Council ⓘ
stateLawChallenged	Oregon ⓘ
statuteInvolved	Oregon Revised Statutes § 111.070 (1963) (formerly § 111.070, Oregon Laws) ⓘ linked to: Oregon Revised Statutes
subjectMatter	escheat of property to the state when foreign heirs could not meet statutory conditions ⓘ
subsequentCitation	frequently cited in cases limiting state action in foreign affairs ⓘ
term	1967 Term ⓘ
vote	9-0 ⓘ

How these facts were elicited

Referenced by (2)

Full triples — surface form annotated when it differs from this entity's canonical label.

Crosby v. National Foreign Trade Council → relatedCase → Zschernig v. Miller ⓘ

Zschernig v. Miller → fullName → Zschernig et al. v. Miller, Administrator ⓘ

linked to: Zschernig v. Miller

All labels observed (2)

How this entity was disambiguated Show

Statements (49)

How these facts were elicited Show

Referenced by (2)

How this entity was disambiguated

How these facts were elicited