Missouri v. Holland
E934445
Missouri v. Holland is a landmark 1920 U.S. Supreme Court decision that upheld the federal government’s power to implement international treaties through national legislation even in areas traditionally regulated by the states.
All labels observed (2)
| Label | Occurrences |
|---|---|
| Missouri v. Holland canonical | 1 |
| State of Missouri v. Holland, United States Game Warden | 1 |
How this entity was disambiguated
This entity first appeared as the object of triple T11576366 — 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: Missouri v. Holland Context triple: [United States Supreme Court cases of the White Court, hasNotableCase, Missouri v. Holland]
-
A.
United States v. Kagama
United States v. Kagama is an 1886 U.S. Supreme Court case that upheld federal authority over crimes committed by Native Americans on reservations, reinforcing congressional power in Indian affairs.
-
B.
Ex parte Milligan
Ex parte Milligan is an 1866 U.S. Supreme Court decision that limited the use of military tribunals for civilians when civil courts are open, reinforcing constitutional protections during wartime.
-
C.
Insular Cases
The Insular Cases are a series of early 20th-century U.S. Supreme Court decisions that defined the constitutional status and rights of residents in American overseas territories.
-
D.
United States v. Curtiss-Wright Export Corp.
United States v. Curtiss-Wright Export Corp. is a landmark 1936 U.S. Supreme Court case that broadly affirmed the president’s independent and plenary authority in conducting foreign affairs.
-
E.
Katzenbach v. Morgan
Katzenbach v. Morgan is a 1966 U.S. Supreme Court case that upheld Congress’s power under the Fourteenth Amendment to prohibit certain state voting restrictions, reinforcing federal authority to protect voting rights.
- 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: Missouri v. Holland Target entity description: Missouri v. Holland is a landmark 1920 U.S. Supreme Court decision that upheld the federal government’s power to implement international treaties through national legislation even in areas traditionally regulated by the states.
-
A.
United States v. Kagama
United States v. Kagama is an 1886 U.S. Supreme Court case that upheld federal authority over crimes committed by Native Americans on reservations, reinforcing congressional power in Indian affairs.
-
B.
Ex parte Milligan
Ex parte Milligan is an 1866 U.S. Supreme Court decision that limited the use of military tribunals for civilians when civil courts are open, reinforcing constitutional protections during wartime.
-
C.
Insular Cases
The Insular Cases are a series of early 20th-century U.S. Supreme Court decisions that defined the constitutional status and rights of residents in American overseas territories.
-
D.
United States v. Curtiss-Wright Export Corp.
United States v. Curtiss-Wright Export Corp. is a landmark 1936 U.S. Supreme Court case that broadly affirmed the president’s independent and plenary authority in conducting foreign affairs.
-
E.
Katzenbach v. Morgan
Katzenbach v. Morgan is a 1966 U.S. Supreme Court case that upheld Congress’s power under the Fourteenth Amendment to prohibit certain state voting restrictions, reinforcing federal authority to protect voting rights.
- F. None of above. chosen
Statements (43)
| Predicate | Object |
|---|---|
| instanceOf |
United States Supreme Court case
ⓘ
federalism case ⓘ landmark case ⓘ treaty power case ⓘ |
| areaOfLaw |
constitutional law
ⓘ
environmental law ⓘ international law ⓘ |
| argumentByMissouri | Regulation of game and wildlife is reserved to the states under the Tenth Amendment. ⓘ |
| authorOfOpinion | Oliver Wendell Holmes Jr. ⓘ |
| citation | 252 U.S. 416 ⓘ |
| constitutionalProvisionInterpreted |
Article II Treaty Clause of the U.S. Constitution
ⓘ
Necessary and Proper Clause ⓘ Tenth Amendment to the U.S. Constitution ⓘ |
| country |
United States
ⓘ
linked to:
United States of America
|
| court | Supreme Court of the United States ⓘ |
| courtTerm | 1919 term of the U.S. Supreme Court ⓘ |
| decisionDate | 1920-04-19 ⓘ |
| decisionType | majority opinion ⓘ |
| fullCaseName |
State of Missouri v. Holland, United States Game Warden
ⓘ
linked to:
Missouri v. Holland
|
| holding |
The Migratory Bird Treaty Act of 1918 is constitutional as an exercise of the treaty power and the Necessary and Proper Clause.
ⓘ
linked to:
Migratory Bird Treaty Act
The federal government may implement valid treaties through national legislation even in areas otherwise reserved to the states. ⓘ |
| importance |
Frequently cited in debates over federalism and international agreements.
ⓘ
Key precedent on the breadth of the federal treaty power. ⓘ |
| jurisdiction |
United States
ⓘ
linked to:
United States of America
|
| languageOfDecision | English ⓘ |
| legalIssue |
federalism and states’ rights
ⓘ
implementation of treaties by Congress ⓘ scope of the federal treaty power ⓘ |
| majorityOpinionBy | Oliver Wendell Holmes Jr. ⓘ |
| petitioner | State of Missouri ⓘ |
| principleEstablished |
Congress may pass laws necessary and proper to implement treaties.
ⓘ
The Tenth Amendment does not limit the treaty power when a treaty is otherwise valid. ⓘ Valid treaties made under the authority of the United States can expand the scope of federal legislative power. ⓘ |
| respondent | Ray P. Holland ⓘ |
| respondentRole | United States game warden ⓘ |
| stateChallengingFederalLaw | Missouri ⓘ |
| statuteInvolved |
Migratory Bird Treaty Act of 1918
ⓘ
linked to:
Migratory Bird Treaty Act
|
| subjectMatter | migratory bird protection ⓘ |
| subsequentInfluence | Cited in later cases concerning the treaty power and federal authority over traditionally state-regulated matters. ⓘ |
| SupremeCourtRejectionOfArgument | The Court rejected Missouri’s claim that the Tenth Amendment barred federal implementation of the treaty. ⓘ |
| treatyInvolved | 1916 Migratory Bird Treaty between the United States and Great Britain ⓘ |
| vote | 7–2 ⓘ |
| yearDecided | 1920 ⓘ |
How these facts were elicited
The pipeline generated the facts above by prompting gpt-5.1 with this entity's name + description and the instruction below.
Instruction
You are a knowledge base construction expert. Given a subject entity and a description of it, return factual statements that you know for the subject as a JSON list of dictionaries(triples), where keys must be "subject", "predicate" and "object". The number of facts may be very high, between 25 to 50 or more, for very popular subjects. For less popular subjects, the number of facts can be very low, like 5 or 10. # Requirements - If you don't know the subject at all, return an empty list. - If the subject is not a named entity, return an empty list. - Include at least one triple where predicate is "instanceOf". - Do not get too wordy. - Separate several objects into multiple triples with one object.
Input
Subject: Missouri v. Holland Description of subject: Missouri v. Holland is a landmark 1920 U.S. Supreme Court decision that upheld the federal government’s power to implement international treaties through national legislation even in areas traditionally regulated by the states.
Referenced by (2)
Full triples — surface form annotated when it differs from this entity's canonical label.
linked to: Missouri v. Holland