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Connell v. Smiley, 1894, is a U.S. Supreme Court case that dealt with the issue of whether or not a state legislature could pass laws to regulate its own procedures for proposing constitutional amendments without violating Article V of the Constitution. The court ruled in favor of Smiley, stating that such legislative processes were indeed within the purview of state legislatures and did not violate federal law. This decision affirmed states' rights to manage their internal affairs and clarified how they can propose changes to their constitutions under Article V.
The dissenting opinion in the Connell v. Smiley case argued that the court's decision to allow a state legislature to unilaterally change its method of appointing electors for presidential elections was unconstitutional. The dissenters believed this violated Article II, Section 1 of the Constitution, which states that each state shall appoint electors "in such manner as the Legislature thereof may direct." They interpreted this clause to mean that once a state has established a method for selecting its electors, it cannot be changed without approval from both houses of the legislature and with proper notice given to citizens. By allowing unilateral changes by one house or even an individual legislator, they feared it would open up potential avenues for corruption and manipulation in future elections.