In Edwards v. California (1941), the U.S. Supreme Court ruled that a California law criminalizing the act of bringing into the state any indigent person who is not a resident was unconstitutional, violating both the Commerce Clause and Fourteenth Amendment's Equal Protection Clause of the Constitution. The case arose when Fred Edwards brought his brother-in-law, an unemployed man from Texas, to California in search for better opportunities during America's Great Depression era. Under California’s "anti-Okie" law aimed at discouraging poor migrants fleeing Dust Bowl conditions from settling in their state, Edwards was convicted and fined $500 for this action. However, on appeal to the Supreme Court it held that such laws were discriminatory as they interfered with interstate migration which is protected under federal jurisdiction by virtue of being considered 'interstate commerce'. This landmark decision established freedom of movement across states as a fundamental right under U.S constitution.

In the dissenting opinion for Edwards v. California, Justice Frank Murphy argued that while he agreed with the majority's decision to strike down a California law criminalizing the transportation of indigent individuals into the state as unconstitutional, he disagreed with their reasoning. He believed that instead of basing their decision on Commerce Clause grounds, they should have focused on individual rights protected by the Fourteenth Amendment. Specifically, Murphy contended that freedom of movement is an essential right inherent in American citizenship and thus protected under this amendment. He also expressed concern about states' ability to discriminate against poor citizens if such laws were allowed to stand and emphasized his belief in equal protection under law regardless of economic status.