United States v. Darby Lumber Co.

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 (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 all
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 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) and limited the application of Carter v. Carter Coal Company, 298 U.S. 238 (1936).

The issue

The issue was whether Congress had overstepped its constitutional authority in creating the Fair Labor Standards Act. An American 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 found 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.

The decision

The Court reversed the appellate court decision. It affirmed the constitutional power 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 held 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 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.

Further reading

• Richter, Irving (1943), "Four Years of the Fair Labor Standards Act of 1938: Some Problems of Enforcement", Journal of Political Economy 51 (2): 95–111, doi:10.1086/256010 .

External links

Works related to United States v. Darby at Wikisource

• ^ Text of United States v. Darby Lumber Co., 312 U.S. 100 (1941) is available from: Justia · Findlaw

• Case Brief for United States v. Darby Lumber Co. at Lawnix.com