form the United States authorities of violations of its
laws.[22] Earlier in a decision not referred to in the aforementioned
enumeration, the Court had also acknowledged that the carrying on of
interstate commerce is "a right which every citizen of the United States
is entitled to exercise."[23]

During the past fifteen years this clause has been accorded somewhat
uneven treatment by the Court which, on two occasions at least, has
manifested a disposition to magnify the restraint which it imposes on
State action by enlarging previous enumerations of the privileges
protected thereby. In Hague _v._ C.I.O.,[24] decided in 1939, the Court
affirmed that freedom to use municipal streets and parks for the
dissemination of information concerning provisions of a federal statute
and to assemble peacefully therein for discussion of the advantages and
opportunities offered by such act was a privilege and immunity of a
United States citizen. The latter privilege was deemed to have been
abridged by city officials who acted in pursuance of a void ordinance
which authorized a director of safety to refuse permits for parades or
assemblies on streets or parks whenever he believed riots could thereby
be avoided and who forcibly evicted from their city union organizers who
sought to use the streets and parks for the aforementioned purposes.[25]
Again in Edwards _v._ California,[26] four Justices[27] who concurred in
the judgment that a California statute restricting the entry of indigent
migrants was unconstitutional preferred to rest their decision on the
ground that the act interfered with the right of citizens to move freely
from State to State. In thus rejecting the commerce clause, relied on by
the majority as the basis for disposing of this case, the minority
thereby resurrected an issue first advanced in the old decision of
Crandall _v._ Nevada[28] and believed to have been resolved in favor of
the commerce clause by Helson and Randolph _v._ Kentucky.[29] Colgate
_v._ Harvey,[30] however, which was decided in 1935 and overruled in
1940,[31] represented the first attempt by the Court since adoption of
the Fourteenth Amendment to convert the privileges and immunities clause
into a source of protection of other than those "interests growing out
of the relationship between the citizen and the national government."
Here the Court declared that the right of a citizen, resident in one
State, to contract in another, to transact any lawful b