United States v. Darby Lumber Co.

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This case is about the Commerce Clause. For the 1931 case about taxation of reduction of debt, see United States v. Kirby Lumber Co.


United States v. Darby Lumber Co.

Supreme Court of the United States
Argued December 19 – 20, 1940
Decided February 3, 1941
Full case name: United States v. Darby Lumber Company
Citations: 312 U.S. 100; 61 S. Ct. 451; 85 L. Ed. 609; 1941 U.S. LEXIS 1222; 3 Lab. Cas. (CCH) P51,108; 132 A.L.R. 1430
Prior history: Appeal from the District Court of the United States for the Southern District of Georgia. Appeal, under the Criminal Appeals Act, from a judgment quashing an indictment
Holding
The Fair Labor Standards Act was a constitutional exercise of Congressional power under the Commerce Clause.
Court membership
Chief Justice: Charles Evans Hughes
Associate Justices: James Clark McReynolds, Harlan Fiske Stone, Owen Josephus Roberts, Hugo Black, Stanley Forman Reed, Felix Frankfurter, William O. Douglas, Frank Murphy
Case opinions
Majority by: Stone
Joined by: unanimous
Laws applied
U.S. Const., art. I, sec. 8; Fair Labor Standards Act

United States v. Darby Lumber Co., 312 U.S. 100 (1941)[1], was a case in which the United States Supreme Court upheld the Fair Labor Standards Act, holding that the U.S. Congress had the power under the Commerce Clause to regulate employment conditions. The unanimous decision of the Court in this case overturned several longstanding precedents, notably Hammer v. Dagenhart, 247 U.S. 251 (1918).

[edit] The issue

At issue was whether the Congress had overstepped its constitutional authority in creating the Fair Labor Standards Act. A lumber company in Georgia that did not meet these standards was charged with violating the law, but had won an appeal, where the appellate judge followed the precedent of Hammer v. Dagenhart finding that the federal government is barred by the 10th Amendment from interfering in matters that are strictly local, that is, within intrastate boundaries. The Act also required the keeping of records to verify compliance; the appellee argued that this violated his 5th Amendment right protecting him from self-incrimination.

[edit] The decision

The Court reversed the appellate court decision. It affirmed the constitutional right of Congress to regulate interstate commerce, which power "can neither be enlarged nor diminished by the exercise or non-exercise of state power." FindLaw. The Court argued that the purpose of the Act was to prevent states from using substandard labor practices to their own economic advantage through interstate commerce. In the Dagenhart case, the Court had made the distinction between manufacturing and interstate commerce, so that a business could argue it was engaging in the former, but had not intended the latter. Twenty-two years later, the Court found that earlier argument facile, explaining that Congress was well aware that businesses produce their goods without thought to where it will go; product is pulled and shipped to meet the orders of the day. The Court went so far as to allow that Congress can control intrastate commerce when it must reasonably do so to effect its regulatory power over interstate commerce. The Court also found that the requirement of record keeping was entirely appropriate as a matter of enforcing the Act.

There were no dissenting opinions in this case.

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