United States v. Darby Lumber Co.

United States v. Darby

Argued December 19–20, 1940
Decided February 3, 1941
Full case name United States v. Darby
Citations

312 U.S. 100 (more)

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 E. Hughes
Associate Justices
James C. McReynolds
Harlan F. Stone · Owen J. Roberts
Hugo Black · Stanley F. Reed
Felix Frankfurter · William O. Douglas
Frank Murphy
Case opinions
Majority Stone, joined by unanimous
Laws applied
U.S. Const. art. I, § 8, Fair Labor Standards Act
This case overturned a previous ruling or rulings
Hammer v. Dagenhart, 247 U.S. 251 (1918)

[1]United States v. Darby Lumber Co., 312 U.S. 100 (1941), was a case in which the United States Supreme Court upheld the Fair Labor Standards Act of 1938, 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 Hammer v. Dagenhart 247 U.S. 251 (1918), limited the application of Carter v. Carter Coal Company 298 U.S. 238 (1936), and confirmed the underlying legality of minimum wages held in West Coast Hotel Co. v. Parrish 300 U.S. 379 (1937).

Background

An American lumber company based in Georgia that did not meet these standards was charged with violating the law. However it successfully appealed when an appellate judge ruled that the federal government is barred by the Tenth Amendment from interfering in matters that are strictly local and within state boundaries.

Darby Lumber, located in Statesboro, Georgia, was founded by entrepreneur Fred Darby in 1919 after the conclusion of World War I. After buying some land from a defunct oil company, Mr. Darby turned his lumber company into one of the premier companies in the area with over 50 employees.[2] The company benefited from the forested land of South Georgia and easy railroad access to nearby Savannah and not too distant Macon. During the boom of the 1920's, and even the bust of the 1930’s, Darby Lumber prospered so well that in 1938 it was able to expand it's operations. The expansion, which included larger facilities and an increased payroll, garnered resources that would make the operations of the company much more efficient. After a year of basking in the success of their expansion, they hit a patch of misfortune that would make history.[2]

The Darby case came about due to its violations of the Fair Labor Standards Act of 1938 (FLSA), one of many initiative enacted by President Franklin D. Roosevelt during the great depression, and the most comprehensive law to date that dictated how corporations could be run. His goal was to unite labor practices in all 48 states because leaving that power to the states proved to be ineffective.[2] There was some fallout about how the new law would affect the viability of businesses. The act was passed in August 1938 and signed into law by Roosevelt two months later. The law addressed businesses that conducted both intrastate and interstate commerce. There are several pieces of this law that should be immediately recognized because they are still in practice today, such as the establishment of a federal minimum wage. Also legislated was the 44-hour work week standard, the slightly longer precedent for the 40 hour work week that we enjoy today. Another benefit given by FLSA that we still enjoy today is overtime pay; which requires employers to pay their hourly-employees at least 150% of their normal wages after the first 44 hours worked in the same week.

Issues

One issue was whether Congress had overstepped its constitutional authority in creating the Fair Labor Standards Act.

Another issue was that the Act required the keeping of records to verify compliance; the appellee argued that this violated his Fifth Amendment right protecting him from self-incrimination.

Decision

The Court unanimously reversed the appellate court decision and affirmed the constitutional power of Congress to regulate interstate commerce, which "can neither be enlarged nor diminished by the exercise or non-exercise of state power." FindLaw. The Court held that the purpose of the Act was to prevent states from using substandard labor practices to their own economic advantage by interstate commerce. In Dagenhart, the Court had made the distinction between manufacturing and interstate commerce so a business could argue it was engaging in the former but had not intended the latter.

In the current case, the Court found that earlier argument facile and explained that Congress was aware that businesses produce their goods without thought to where they will go, and product is pulled and shipped to meet the orders of the day. The Court also concluded that the requirement to keep records was entirely appropriate, as a matter of enforcing the Act.

The Court ruled that Congress could require companies to conform to production regulation under the FLSA. The Court also ruled that the employer could be held responsible for transgressions of the law and that the employer had to keep a record of his compliance with the law.[1]

Further reading

References

  1. 1 2 United States Reports 312. United States Supreme Court. 1941. pp. 124–25.
  2. 1 2 3 Novotny, Dr. Patrick “United States vs Darby Lumber Company: Statesboro, Georgia 1939- 1941” Statesboro Magazine March April 2005.

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