Easton v. Iowa
Annotate this Case
188 U.S. 220 (1903)
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U.S. Supreme Court
Easton v. Iowa, 188 U.S. 220 (1903)
Easton v. Iowa
Argued January 14-15, 1903
Decided February 2, 1903
188 U.S. 220
Congress, having power to create a system of national banks, is the judge as to the extent of the powers which should be conferred upon such banks, and has the sole power to regulate and control the exercise of their operations. Congress having dealt directly with the insolvency of national banks by giving control to the Secretary of the Treasury and the Comptroller of the Currency, who are authorized to suspend the operations of the banks and appoint receivers thereof when they become insolvent or when they fail to make good any impairment of capital, and full and adequate provision having been made for the protection of creditors of national banks by requiring frequent reports to be made of their condition, and by the power of visitation of federal officers, it is not competent for state legislatures to interfere, whether with hostile or friendly intentions, with national banks or their officers in the exercise of the powers bestowed upon them by the general government.
While a state has the legitimate power to define and punish crimes by general laws applicable to all persons within its jurisdiction, and it may declare, by special laws, certain acts to be criminal offences when committed by officers and agents of its own banks and institutions, it is without lawful power to make such special laws applicable to banks organized and operated under the laws of the United States.
In 1898, in the District Court of Winneshiek County, State of Iowa, James H. Easton was indicted,
tried, and found guilty, and sentenced to imprisonment in the Penitentiary of Iowa at hard labor for a term of five years under the provisions of a statute of that state for the offense of having received, as president of the First National Bank of Decorah, Iowa, a deposit of one hundred dollars in money in said bank at a time when the bank was insolvent, and when such insolvency was known to the defendant.
At the trial, it was contended on behalf of the defendant that the statute of Iowa upon which the indictment was found did not, and was not intended to, apply to national banks organized and doing business under the National Bank Acts of the United States, or to the officers and agents of such banks, and that, if the state statute should be construed and held to apply to national banks and their officers, the statute was void insofar as made applicable to national banks and their officers. Both these contentions were overruled by the trial court, and thereupon an appeal was taken to the Supreme Court of the State of Iowa, and by that court, on April 12, 1901, the judgment of the district court was affirmed. The cause was then brought to this Court by a writ of error allowed by the Chief Justice of the Supreme Court of Iowa.