Hammer v. Dagenhart
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| Hammer v. Dagenhart | ||||||||||||
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| Argued April 15 – 16, 1918 Decided June 3, 1918 |
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| Holding | ||||||||||||
| Congress has no power under the Commerce Clause to regulate labor conditions. | ||||||||||||
| Court membership | ||||||||||||
| Chief Justice: Edward Douglass White Associate Justices: Joseph McKenna, Oliver Wendell Holmes, Jr., William R. Day, Willis Van Devanter, Mahlon Pitney, James Clark McReynolds, Louis Brandeis, John Hessin Clarke |
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| Case opinions | ||||||||||||
| Majority by: Day Joined by: White, Pitney, Van Devanter, McReynolds Dissent by: Holmes Joined by: McKenna, Brandeis, Clarke |
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| Laws applied | ||||||||||||
| Keating-Owen Act of 1916; Commerce Clause of the U.S. Const. | ||||||||||||
| Overruled by | ||||||||||||
| United States v. Darby Lumber Co., | ||||||||||||
Hammer v. Dagenhart, 247 U.S. 251 (1918), was a United States Supreme Court decision involving the power of Congress to enact child labor laws.
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[edit] Background
Unable to regulate hours and working conditions for child labor within individual states, Congress sought to regulate child labor by banning the product of that labor from interstate commerce. The Keating-Owen Act of 1916 prohibited interstate commerce of any merchandise that had been made by children under the age of fourteen, or merchandise that had been made in factories where children between the ages of 14 and 16 worked for more than eight hours a day, worked overnight, or worked more than six days a week. Roland Dagenhart, who worked in a cotton mill in Charlotte, North Carolina with his two sons, sued, arguing that this law was unconstitutional.
At issue: Does Congress have the right to regulate commerce of goods that are manufactured by children under the age 14, as specified in the Keating-Owen Act of 1916, and is it within the authority of Congress in regulating commerce among the states to prohibit the transportation in interstate commerce of manufactured goods by the child labor description above?
[edit] Supreme Court decision
Justice Day, with the Majority Opinion, said that Congress does not have the right to regulate commerce of goods that are manufactured by children, therefore voiding the Keating-Owen Act of 1916. Drawing a distinction between the manufacture of goods and potential "inherent evil" of goods themselves introduced into interstate commerce, the Court maintained that the issue was not a moral one, removing it from precedents set in previous cases where the Congress had sought to control lottery schemes, prostitution, and liquor. The Court reasoned that such instances were inherently 'evil' and thus open to Congressional scrutiny. In this case, however, the issue at hand was the manufacture of cotton, which does not entail a moral evil. The Court further argued that the manufacture of cotton did not in itself constitute interstate commerce. The Court recognized that disparate labor regulations placed the various states on unequal ground in terms of economic competitiveness, but it specifically stated that Congress could not address such inequality: "The commerce clause was not intended to give to Congress a general authority to equalize such conditions." FindLaw The Court held that the federal government was "one of enumerated powers" and could not go beyond the boundary drawn by the 10th Amendment.
[edit] Dissenting opinion
Justice Holmes dissented strongly from the logic and ruling of the majority. He maintained that Congress was completely within its right to regulate interstate commerce, and that goods manufactured in one state and sold in other states were by definition interstate commerce. This places the entire manufacturing process under the purview of Congress, and this constitutional power "could not be cut down or qualified by the fact that it might interfere with the carrying out of the domestic policy of any State." (Ibid) Holmes also took issue with the majority's logic in allowing Congress to regulate activities regarded as immoral, while at the same time disallowing the same in other cases: "The notion that prohibition is any less prohibition when applied to things now thought evil I do not understand...to say that it is permissible as against strong drink but not as against the product of ruined lives." (Ibid)
[edit] Later developments
The ruling of the Court was later overturned and repudiated in a series of decisions handed down in the late 1930s. Specifically, Hammer v. Dagenhart was overruled in 1941 in the case of United States v. Darby Lumber Co., . The Court in the Darby case sided strongly with Holmes' dissent, which they named "classic". They also recast the reading of the 10th Amendment, regarding it as a "truism" that merely restates what the Constitution had already provided for, rather than offering a substantive protection to the States, as the Hammer ruling had contended.
