The case challenged the constitutionality of Alaska's "Alaska Hire" statute, which required private firms working on oil and gas projects to give hiring preference to Alaska residents.
The Supreme Court unanimously ruled that the Alaska Hire law violated the Privileges and Immunities Clause of the U.S.
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Constitution, which protects the rights of citizens from one state when they are in another state.
The Court's decision was based on the precedent set in Toomer v.
Witsell (1948), which had established a framework for analyzing state laws that discriminate against non-residents.
In Hicklin v.
Orbeck, the Court found that the Alaska Hire law was not sufficiently tailored to the state's interest in ensuring its citizens benefit from the development of its natural resources.
The Court's ruling invalidated Alaska's attempt to preference its own residents in the utilization of the state's natural resources, which the majority viewed as unconstitutional economic protectionism.
The decision was written by Justice William J.
Brennan Jr., who emphasized the importance of the Privileges and Immunities Clause in preserving the national economic union.
The case highlighted the tension between a state's interest in developing its natural resources and the constitutional prohibition on discriminating against non-resident citizens.
Hicklin v.
Orbeck was the first time the Supreme Court had directly addressed the constitutionality of a state's "local hire" law in the context of the Privileges and Immunities Clause.
The Court's ruling in Hicklin v.
Orbeck set an important precedent that has been cited in numerous subsequent cases involving state laws that discriminate against non-residents.
The decision underscored the Supreme Court's role in enforcing the Privileges and Immunities Clause as a check on state power and a safeguard of national unity.
Hicklin v.
Orbeck highlighted the potential for tension between a state's desire to promote the economic interests of its own citizens and the constitutional requirement of equal treatment for all U.S.
citizens.
The case demonstrated the Court's willingness to scrutinize state laws that appear to be protectionist in nature and to strike down those that cannot be justified by a substantial state interest.