United States v. Darby Lumber Co.
312 U.S. 100 (1941)
Darby failed to meet the
standards of the Fair Labor Act,
and was charged with violating the law.
The Trial Court convicted
Darby of violating the Fair Labor Act.
Darby argued that the Fair
Labor Act was unconstitutional
because Congress couldn't use the Interstate Commerce Clause
to reach businesses that weren't involved in interstate commerce.
The Appellate Court reversed.
The US appealed.
The Appellate Court found
the Fair Labor Act to be
The Court followed the
precedent of Hammer v. Dagenhart
(247 U.S. 251 (1918)) which said that the Federal government is barred by
the 10th Amendment from
interfering in matters that are strictly local, that is, within
Darby only sold lumber
locally, so based on the logic of Hammer, they were not involved in interstate commerce and were beyond
the reach of the Interstate Commerce Clause.
The Fair Labor Act also required the keeping of records to
verify compliance. Darby argued that this violated his 5th
Amendment right protecting him from
The US Supreme Court reversed
and found the Fair Labor Act to be
The US Supreme Court
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."
The Court found that the
purpose of the Fair Labor Act was
to prevent States from using substandard labor practices to their own economic
advantage through interstate commerce. That was enough to make it
permissible under the Interstate Commerce Clause.
In Hammer, 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
Here, the Court changed
their mind, explaining that Congress was well aware that businesses
produce their goods without thought to where it will go since products
are pulled and shipped to meet the orders of the day.
The Court found that
Congress can control intrastate commerce when it must reasonably do so to affect 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 Fair
This was a significant
reversal over previous decisions, such as A.L.A. Schechter Poultry
Corp. v. United States (295 U.S.
495 (1935)), and Carter v. Carter Coal Co. (298 U.S. 238 (1936)).
The Court reasoned that because
Congress has the power to completely bar interstate shipments under the
doctrine of necessary and proper, they must have the ability to do things
that will effectively bar shipments, by doing things such as passing
minimum wage laws.
This case for the most part
decided that the 10th Amendment is
more rhetoric than anything else and can mostly be ignored.